In 2025, we published dozens of articles on our blog that provide important insights and practical information for high-income and high-net-worth taxpayers. The Internal Revenue Service (IRS) places particular emphasis on targeting high-income and high-net-worth taxpayers suspected of noncompliance, and facing IRS scrutiny can expose these taxpayers to substantial liability. […]
Category: IRS
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 […]
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’ […]
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 […]
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 […]
While the Internal Revenue Service (IRS) has several tools that it can use to enforce taxpayer compliance, one of its most effective tools is its power to seize, or levy, taxpayers’ assets. For high-income and high-net-worth taxpayers who are behind (or allegedly behind) on their federal tax obligations, facing an […]
While it remains to be seen what will happen to the Internal Revenue Service’s (IRS) enforcement resources in the coming months and years, at present, the IRS is continuing to actively target taxpayers and tax preparers for all forms of fraud. This includes fraud under pandemic-era programs. As Texas tax […]
What should you do if you discover that you made mistakes on last year’s federal returns when doing your taxes in 2025? Or, what if you already knew that you made mistakes, and you want to address them so that you are not at risk in the event of an […]