Internal Revenue Service (IRS) audits can present substantial risks, especially for high-income and high-net-worth taxpayers. Not only can revenue agents impose liability for back taxes, interest, and penalties, but if they uncover apparent evidence of an intentional unlawful tax avoidance scheme, they can engage Special Agents from IRS Criminal Investigation […]
Author: Lawrence Brown
Under federal law, U.S. taxpayers who hold qualifying offshore accounts (and certain other foreign financial assets) must report these assets to the U.S. Treasury on an annual basis. In many cases, taxpayers must file two separate forms—with two separate federal entities—to meet their reporting obligations. One of these forms, the […]
Each year, we publish dozens of articles with insights for high-income and high-wealth U.S. taxpayers on our blog. This past year was no exception. Here is a look back at some of the key compliance insights Texas IRS dispute lawyer Lawrence Brown shared in 2024: Resolving Offshore Account Disclosure Violations […]
For businesses that claimed the Employee Retention Credit (ERC) or received a Paycheck Protection Program (PPP) loan or Economic Injury Disaster Loan (EIDL), facing scrutiny from the Internal Revenue Service (IRS) remains a very real concern. The IRS is continuing to aggressively target pandemic-era fraud heading into 2025—pursuing audits and […]
The Internal Revenue Service (IRS) recently released two end-of-year reports highlighting its enforcement efforts during the 2024 fiscal year. In the IRS’s own words, these reports reflect the agency’s “global reach” and “billion-dollar impact” and “outlin[e] key milestones in criminal investigations . . . and advancements in digital modernization that […]
It’s the end of another year. While this is a time when many people do some last-minute tax planning, it is also a time when many people make all-too-common tax mistakes. The Internal Revenue Service (IRS) is intimately familiar with these mistakes—and it looks for them when examining taxpayers’ returns […]
U.S. taxpayers who own offshore accounts have annual filing obligations that do not apply to other taxpayers. As failing to meet these filing obligations can potentially trigger civil or criminal penalties, it is imperative that offshore account holders prioritize compliance. With the end of 2024 fast approaching, what do offshore […]
Understanding FinCEN’s Beneficial Ownership Reporting Requirements (and the Risks of Non-Compliance)
In the summer of 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) launched a communications campaign “to educate the small business community about new beneficial ownership reporting requirements.” For existing companies, the obligation to file beneficial ownership reports with FinCEN took effect on January 1, 2024. For companies […]
The Internal Revenue Service (IRS) recently released its 2024 Financial Report. While the report “highlights the programs, accomplishments, challenges and management’s accountability for the resources entrusted to the IRS,” it also provides insight into the IRS’ enforcement priorities heading into 2025. Learn more from Texas IRS lawyer Lawrence Brown: Enforcement […]
While partnerships have long been on the Internal Revenue Service’s (IRS) enforcement radar, it has lacked the funding needed to target partnerships at scale and effectively audit large partnerships with billions of dollars in assets and annual revenue. But, this changed with the enactment of the Inflation Reduction Act in […]