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 […]
Category: IRS
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 […]
With Tax Day just around the corner, now is a time of year when many people, particularly high-income and high-net-worth taxpayers, begin to have concerns about the possibility of facing an IRS audit. Even if you do your best to meet your federal tax obligations—and even if you rely on […]
If you are facing substantial tax debt in 2025, you will want to take a proactive approach to dealing with the Internal Revenue Service (IRS). The IRS has various options for enforcing taxpayers’ financial obligations, and tax liens, levies, and other collection mechanisms can present significant challenges and hardships. In […]
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 […]