The Internal Revenue Service (IRS) is continuing to prioritize Employee Retention Credit (ERC) compliance—both through enforcement and through initiatives offering claimants the opportunity to self-correct before their ERC filings trigger scrutiny. On August 15, 2024, the IRS announced that it is reopening its ERC Voluntary Disclosure Program (ERC VDP), and […]
In a recent News Release, the Internal Revenue Service (IRS) touts its efforts to collect past-due taxes from high-net-worth taxpayers. According to the News Release, which the IRS published on July 11, 2024, the IRS “has surpassed the $1 billion mark in collections from high-wealth taxpayers with past-due taxes” since […]
If you are a high-income or high-net-worth taxpayer and you have concerns about the IRS collecting your tax debt, you should discuss your situation with an experienced Texas tax collection attorney as soon as possible. While you have options available, you will need to choose the best option for your […]
In a recent News Release, the Internal Revenue Service (IRS) announced that it plans to crack down on the abuse of partnership tax “loopholes” over the coming years. As the News Release states: “As part of ongoing efforts to focus more attention on high-income compliance issues, the Internal Revenue Service […]
The Internal Revenue Service (IRS) has announced a new enforcement initiative focused on high-income non-filers. According to a recent News Release, the IRS is specifically targeting high-income taxpayers who failed to file returns between 2017 and 2021. As the IRS calculates failure-to-file and failure-to-pay penalties based on the amount due, […]
A recent article on Forbes.com discusses a lawsuit filed against the Internal Revenue Service (IRS) that seeks to force the agency to lift its moratorium on new Employee Retention Credit (ERC) claims. The IRS imposed its moratorium last September amidst concerns of widespread fraud under the ERC program, and, according […]
If you received an unfavorable audit determination from the Internal Revenue Service (IRS), challenging the outcome of your audit will involve filing an appeal. In most cases, this starts with filing a “protest” with the appropriate IRS office. Before you file, however, you need to ensure that doing so is […]
The Internal Revenue Service (IRS) recently released its annual update to its Strategic Operating Plan. While several aspects of the annual update are notable, perhaps the most notable aspect is its focus on targeting high-income and high-net-worth taxpayers. In a News Release accompanying the release of the annual report, the […]
High-income and high-net-worth U.S. taxpayers who have assets held overseas have an obligation to report these assets to the U.S. Treasury Department. Specifically, taxpayers must report their offshore accounts to the Treasury’s Financial Crimes Enforcement Network (FinCEN), and they must report their “foreign financial assets” (which include offshore accounts) to […]
For high-income and high-net-worth U.S. taxpayers who are at risk of facing criminal prosecution due to willful tax law violations, making a voluntary disclosure to IRS Criminal Investigation (IRS CI) can facilitate a favorable resolution that avoids formal charges. But, making a voluntary disclosure presents its own risks—and it isn’t […]