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 […]
Tax evasion is a serious federal crime. Individual taxpayers convicted of tax evasion can face up to a $100,000 fine and five years of federal imprisonment, while corporate entities can be fined up to $500,000. This raises an important question: What does it mean to “attempt to evade or defeat […]
Just like taxpayers, tax preparers have an obligation to comply with the Internal Revenue Code (IRC). Several provisions in the IRC speak specifically to the tax preparer’s role in preparing and submitting fraudulent returns—and tax preparers can face both civil and criminal penalties for aiding and abetting federal tax law […]