The IRS’ Voluntary Disclosure Practice provides a pathway to avoid criminal prosecution when you have willfully violated federal law. But strict eligibility requirements apply—including strict timelines. Even if you don’t know you are no longer eligible, submitting a voluntary disclosure too late lets the IRS use it against you. Willfully […]
Category: IRS
The Internal Revenue Service (IRS) is continuing to aggressively target businesses suspected of Paycheck Protection Program (PPP) and Employee Retention Credit (ERC) fraud in 2026. While the PPP and ERC were pandemic-era programs, widespread fraud has resulted in ongoing enforcement—including criminal enforcement in many cases. Exposing fraud under the pandemic-era […]
The Internal Revenue Service (IRS) recently published two press releases touting the success of its enforcement efforts in 2025. While these press releases highlight the IRS’ enforcement initiatives over the past year, they also provide insight into the IRS’ ongoing enforcement priorities heading into 2026. Here are some key insights […]
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. […]
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 […]