The IRS’ Voluntary Disclosure Practice is one of a handful of options available to high-income taxpayers that need to proactively resolve high-stakes federal tax controversies. If successful, submitting a voluntary disclosure can substantially mitigate a high-income taxpayer’s liability while also eliminating the risk of facing an audit or investigation related […]
Author: Lawrence Brown
The Internal Revenue Service (IRS) recently published a set of frequently asked questions (FAQs) addressing its ongoing efforts to combat fraud under the pandemic-era Employee Retention Credit (ERC) program. While the IRS’ FAQs focus primarily on a new limitation on the ERC established under the One Big Beautiful Bill (OBBB), […]
On October 1, 2025, the Internal Revenue Service (IRS) announced the launch of a two-year pilot program that is designed “to make Post Appeals Mediation (PAM) more attractive to taxpayers.” Post-Appeals Mediation is one of a handful of options available to individual and corporate taxpayers who disagree with the IRS’ […]
The Paycheck Protection Program (PPP) was a pandemic-era program intended to help companies keep their employees on payroll as the economy faltered. The program was open for portions of 2020 and 2021, and it allowed eligible companies to apply for forgivable government-backed loans from participating financial institutions. Why, then, are […]
Requesting a private letter ruling (PLR) from the IRS’ Office of Chief Counsel is an option for large businesses and international taxpayers seeking to “determine the tax treatment of a specific situation” without facing an audit. It is one of several pre-filing and pre-resolution audits that are available to eligible […]
For large businesses and international taxpayers, the IRS’ Pre-Filing Agreement (PFA) program provides a way to “seek an agreement on issues likely to be disputed in post-filing audits.” Eligible taxpayers can use the PFA to address tax concerns related to specific transactions, or they can use the PFA to seek […]
For large business and international taxpayers, filing a return with the Internal Revenue Service (IRS) will frequently lead to post-filing scrutiny. This scrutiny can take a variety of forms, from informal inquiries to invasive audits and criminal tax investigations. When facing post-filing scrutiny (or the risk of post-filing scrutiny), a […]
The Internal Revenue Service (IRS) offers a variety of options to large business and international taxpayers that need to resolve tax controversies at the pre-filing or pre-audit stage. These options are specifically tailored to taxpayers that fall under the jurisdiction of the IRS’s Large Business and International (LB&I) Division, which […]
Even though it has now been more than two years since the federal government ended its national emergency declaration for the COVID-19 pandemic, targeting COVID-19 relief fraud remains a top priority for IRS Criminal Investigation (IRS CI). Specifically, IRS CI is continuing to target both individual and corporate taxpayers for […]
On June 17, 2025, the Internal Revenue Service (IRS) announced that it was making various improvements to its Pre-Filing Agreement program for large businesses and international taxpayers. According to the announcement, these improvements reflect “a renewed commitment by the IRS to expand access to cooperative tax compliance strategies that prevent […]