The Internal Revenue Service (IRS) conducts most audits and reviews remotely. The IRS is responsible for enforcing more than 150 million taxpayers’ obligations, and, as a result, it simply does not have the resources to visit all delinquent taxpayers in person. As a result, receiving an in-person visit from the […]
Author: Lawrence Brown
If you have been contacted by Special Agents from the Internal Revenue Service’s Criminal Investigation division (IRS CI), one of the first questions you need to answer is, “Why?” IRS CI investigates a broad range of both tax-related and non-tax-related offenses, and determining the specific accusations underlying an IRS CI […]
While IRS Criminal Investigation (IRS CI) targets taxpayers for a broad range of federal offenses, many of its investigations are centered on allegations of tax evasion. These allegations can stem from IRS audits, whistleblower complaints, referrals from other federal agencies, and a variety of other sources, and, regardless of their […]
If you’re like most high-income individuals, you rely on an accountant or other tax professional to prepare your federal tax returns. In doing so, you trust that your tax professional will do the right thing, and accurately calculate your tax liability while taking advantage of the various credits, deductions and […]
Tax planning is crucial for high-income individuals. While the Internal Revenue Code imposes substantial tax liability for those who are in the one percent, it also provides opportunities for high-income taxpayers to lawfully reduce the amount they owe. The Internal Revenue Service (IRS) refers to this as “tax avoidance,” and […]
When companies collect payroll taxes from their employees, they hold their employees’ funds “in trust” pending remittance to the IRS. When companies fail to timely remit their employees’ funds held in trust, they can face substantial liability—including liability for the IRS’ trust fund recovery penalty (TFRP). While the IRS often […]
In 2022, IRS Criminal Investigation (IRS CI) identified $5.7 billion in tax fraud and $26.9 billion in other financial crimes. It executed 1,210 warrants and referred 1,837 cases to the U.S. Department of Justice (DOJ) for prosecution. These referrals resulted in a conviction rate of 90.6 percent. These statistics are […]
According to data cited in a recent NPR article, as much as $64 billion of the $800 billion in forgivable loans issued under the Paycheck Protection Program (PPP) may have gone to applicants that didn’t deserve it. As the article also notes, the federal government has up to 10 years […]
Facing scrutiny from IRS Criminal Investigation (IRS CI) is a serious matter. As its name suggests, IRS CI is tasked with uncovering—and assisting in the prosecution of—criminal violations of the Internal Revenue Code (IRC). But, IRS CI’s investigative authority also extends far beyond the IRC, and it routinely announces investigations […]
U.S. taxpayers who own offshore accounts and certain other foreign financial assets have an obligation to disclose these assets to the Internal Revenue Service (IRS)—provided that their value exceeds the IRS’ relatively modest reporting thresholds. Depending on the nature of a taxpayer’s foreign financial assets, this may entail two separate […]