The Internal Revenue Service (IRS) recently released two end-of-year reports highlighting its enforcement efforts during the 2024 fiscal year. In the IRS’s own words, these reports reflect the agency’s “global reach” and “billion-dollar impact” and “outlin[e] key milestones in criminal investigations . . . and advancements in digital modernization that […]
It’s the end of another year. While this is a time when many people do some last-minute tax planning, it is also a time when many people make all-too-common tax mistakes. The Internal Revenue Service (IRS) is intimately familiar with these mistakes—and it looks for them when examining taxpayers’ returns […]
U.S. taxpayers who own offshore accounts have annual filing obligations that do not apply to other taxpayers. As failing to meet these filing obligations can potentially trigger civil or criminal penalties, it is imperative that offshore account holders prioritize compliance. With the end of 2024 fast approaching, what do offshore […]
Understanding FinCEN’s Beneficial Ownership Reporting Requirements (and the Risks of Non-Compliance)
In the summer of 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) launched a communications campaign “to educate the small business community about new beneficial ownership reporting requirements.” For existing companies, the obligation to file beneficial ownership reports with FinCEN took effect on January 1, 2024. For companies […]
The Internal Revenue Service (IRS) recently released its 2024 Financial Report. While the report “highlights the programs, accomplishments, challenges and management’s accountability for the resources entrusted to the IRS,” it also provides insight into the IRS’ enforcement priorities heading into 2025. Learn more from Texas IRS lawyer Lawrence Brown: Enforcement […]
While partnerships have long been on the Internal Revenue Service’s (IRS) enforcement radar, it has lacked the funding needed to target partnerships at scale and effectively audit large partnerships with billions of dollars in assets and annual revenue. But, this changed with the enactment of the Inflation Reduction Act in […]
The Internal Revenue Service’s Criminal Investigation Division (IRS CI) conducts investigations focused on all forms of criminal tax evasion and tax fraud. But, its enforcement jurisdiction is also much broader, and it routinely works with the U.S. Department of Justice (DOJ) and other federal authorities to substantiate charges for a […]
The Internal Revenue Service (IRS) confirmed this month that it will be classifying syndicated conservation easements as abusive tax transactions going forward. While syndicated conservation easements have long been a red flag for the IRS, this new development increases the risks for taxpayers who rely on syndicated conservation easements to […]
The Internal Revenue Service (IRS) released its “tax gap” projections for the 2022 tax year on October 10, 2024. As the IRS explains in its News Release, the tax gap, which is an estimated $696 billion, “reflects the difference between projected ‘true’ tax liability and the amount of tax that […]
Even with 2025 fast approaching, Employee Retention Credit (ERC) fraud enforcement remains a top priority for the Internal Revenue Service (IRS). As we have discussed previously, the IRS has identified billions—and potentially trillions—of dollars in taxpayer losses resulting from ERC fraud, and it is now working to claw back as […]