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Changes to IRS Examinations of Large Corporate Taxpayers: A Sea Change or Whistling in the Wind?

On July 23, 2025, the IRS issued guidance on audits of large corporate taxpayers. This guidance falls squarely in line with previous IRS statements at conferences, as well as its prior guidance about making examinations more...more

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

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