The Internal Revenue Service (IRS) routinely targets high-income and high-net-worth taxpayers suspected of using abusive tax shelters to evade federal tax liability. Abusive tax shelters fall into several categories, the broadest of which are the IRS’ “Listed Transactions.” As federal tax audits and investigations targeting Listed transactions can present substantial […]
The Internal Revenue Service (IRS) is continuing to target Employee Retention Credit (ERC) fraud in 2024. While the ERC was originally intended as a pandemic-era relief program, limited oversight allowed a substantial volume of fraudulent claims, and promoter schemes led many business owners to unknowingly claim credits for which their […]
High-income and high-net-worth taxpayers who have assets offshore must report these assets to the U.S. government annually. For most, this means filing both IRS Form 8938 to comply with the Foreign Account Tax Compliance Act (FATCA) and a Report of Foreign Bank and Financial Accounts (FBAR) to comply with the […]
While the national public health emergency related to the COVID-19 pandemic may have ended in 2023, combating COVID-related fraud remains a top federal law enforcement priority in 2024. The Internal Revenue Service (IRS) is one of several agencies involved in the government’s ongoing response, and IRS Criminal Investigation (IRS CI) […]
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to conduct “dozens of audits on business aircraft involving personal use” throughout the year. Citing the IRS’ additional funding under the Inflation Reduction Act, the News Release quotes IRS Commissioner Danney Werfel as stating: “With expanded resources, […]
The Internal Revenue Service (IRS) recently issued a News Release in which it advises employers to resolve any issues with their Employee Retention Credit (ERC) filings by March 22, 2024. This is the deadline to file under the IRS’ limited-time ERC Voluntary Disclosure Program (VDP). But, filing under the ERC […]
The Internal Revenue Service (IRS) is continuing to prioritize cryptocurrency-related compliance in 2024. As we previously discussed, the IRS identified digital asset compliance as one of its three “priority areas” for enforcement in 2024, and it recently issued a News Release reminding U.S. taxpayers of the obligation to report cryptocurrency […]
Most U.S. taxpayers who own offshore accounts have a legal obligation to disclose these accounts to the federal government on an annual basis. In most cases, taxpayers must separately report their offshore accounts to the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN), which is also part […]
Failing to file all necessary returns and pay all federal taxes when due can expose U.S. taxpayers to interest and penalties. This includes not only civil penalties but also criminal penalties in some cases. Interest and civil penalties begin to accrue immediately upon noncompliance, while criminal penalties can result from […]
The Internal Revenue Service (IRS) recently launched its highly anticipated Employee Retention Credit Voluntary Disclosure Program (ERC VDP). Under the ERC VDP, eligible businesses can resolve improper ERC claims without liability for interest or penalties. However, filing under the ERC VDP can be risky, and it isn’t the best option […]