The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]
Author: Lawrence Brown
When seeking to close the tax gap through enforcement, the Internal Revenue Service (IRS) doesn’t solely target taxpayers who have underreported and underpaid their federal tax liability. It also targets those who facilitate tax evasion and tax fraud. Accountants, advisors and promoters can all face heavy-handed enforcement; and, when targeted […]
The Internal Revenue Code requires U.S. taxpayers to disclose certain transactions resulting in significant losses. The Internal Revenue Service (IRS) classifies these as “reportable transactions” due to their potential to serve as abusive tax shelters; and, as the IRS makes clear, “[e]ach taxpayer that has participated in a reportable transaction […]
The Internal Revenue Service (IRS) routinely targets high-income and high-net-worth taxpayers suspected of using abusive tax shelters to evade federal tax liability. Abusive tax shelters fall into several categories, the broadest of which are the IRS’ “Listed Transactions.” As federal tax audits and investigations targeting Listed transactions can present substantial […]
The Internal Revenue Service (IRS) is continuing to target Employee Retention Credit (ERC) fraud in 2024. While the ERC was originally intended as a pandemic-era relief program, limited oversight allowed a substantial volume of fraudulent claims, and promoter schemes led many business owners to unknowingly claim credits for which their […]
High-income and high-net-worth taxpayers who have assets offshore must report these assets to the U.S. government annually. For most, this means filing both IRS Form 8938 to comply with the Foreign Account Tax Compliance Act (FATCA) and a Report of Foreign Bank and Financial Accounts (FBAR) to comply with the […]
While the national public health emergency related to the COVID-19 pandemic may have ended in 2023, combating COVID-related fraud remains a top federal law enforcement priority in 2024. The Internal Revenue Service (IRS) is one of several agencies involved in the government’s ongoing response, and IRS Criminal Investigation (IRS CI) […]
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to conduct “dozens of audits on business aircraft involving personal use” throughout the year. Citing the IRS’ additional funding under the Inflation Reduction Act, the News Release quotes IRS Commissioner Danney Werfel as stating: “With expanded resources, […]
The Internal Revenue Service (IRS) recently issued a News Release in which it advises employers to resolve any issues with their Employee Retention Credit (ERC) filings by March 22, 2024. This is the deadline to file under the IRS’ limited-time ERC Voluntary Disclosure Program (VDP). But, filing under the ERC […]
The Internal Revenue Service (IRS) is continuing to prioritize cryptocurrency-related compliance in 2024. As we previously discussed, the IRS identified digital asset compliance as one of its three “priority areas” for enforcement in 2024, and it recently issued a News Release reminding U.S. taxpayers of the obligation to report cryptocurrency […]