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Audits Internal Revenue Service

Holland & Knight LLP

IRS Releases Guidelines for Speeding Up Audits of Large Businesses

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The IRS has issued new guidance to its Large Business and International Division (LB&I) in an attempt to expedite audits. The interim guidance, released on July 23, 2025, outlines procedural changes that will further...more

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

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Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Eversheds Sutherland (US) LLP

IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs

On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more

Mayer Brown

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

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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

White & Case LLP

Goodbye to the IRS AOF Information Document Request

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On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance announcing changes to the Large Business & International Division ("LB&I") audit procedures (see the IRS's memorandum, here). The changes aim to...more

Fox Rothschild LLP

IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement

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The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the new...more

Fenwick & West LLP

IRS Memo Directs Agents to Speed Up Audits

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A recent memo from the IRS's Large Business and International (LB&I) Division indicates an intention to resolve audits efficiently and provide taxpayers with opportunities to quickly settle and resolve issues....more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Oberheiden P.C.

5 Key Considerations for Defending Against Low Income Housing Tax Credit (LIHTC) Fraud Allegations

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Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more

White & Case LLP

Tax-Exempt Organizations Should Prepare Now For An IRS Tax Audit

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It is an uncertain time to be a tax-exempt public charity or private foundation. The federal government has recently scrutinized certain tax-exempt organizations (see here), and draft congressional legislation proposed a tax...more

Fox Rothschild LLP

Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

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The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for the upcoming fiscal...more

Eversheds Sutherland (US) LLP

IRS re-commits to pre-filing agreements

On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more

Ice Miller

Uncertainty at the IRS: Why Qualified Pension Plans Should Self-Audit

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The Internal Revenue Service (IRS) began terminations of employees on February 20, 2025, with initial news reports of layoffs set to 6,000 terminations and a stated intent to downsize its workforce by upwards of 50 percent as...more

Farella Braun + Martel LLP

REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations

Welcome to EO Radio Show – Your Nonprofit Legal Resource. Many nonprofits today are worried about recent federal actions that may bring governmental scrutiny to their stated charitable mission and activities, such as audits,...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

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Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

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As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Cooley LLP

Trump’s Initiative to Revoke Harvard’s Tax-Exempt Status: Implications for Higher Education

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President Donald Trump has repeatedly threatened to strip the tax-exempt status from colleges and universities. Most recently, on May 2, Trump announced in a social media post, “We are going to be taking away Harvard’s Tax...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Steptoe & Johnson PLLC

Can the IRS Revoke a University's Tax-Exempt Status Overnight?

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As a result of President Trump’s recent social media posts regarding Harvard University’s tax-exempt status, some institutions of higher education (IHE) have expressed concerns over whether the Internal Revenue Service (IRS)...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Gambling against a government audit is a bad bet

I love Las Vegas. Great restaurants, great shows, and five trips in a row without dropping a nickel into a slot machine. Why? Because I hate gambling. I hate losing even more. Honestly, just getting out of bed every morning...more

ArentFox Schiff

IRS Workforce Reductions: Delays and Increased Legal Challenges

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A May 2 report from the US Treasury Inspector General for Tax Administration (TIGTA) found that as of March, the Internal Revenue Service (IRS) workforce had fallen by 11,443 employees, or 11%, due to probationary employee...more

Lippes Mathias LLP

Where's My Employee Retention Credit?

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In the years since COVID-19 shut down the country, many businesses applied for the Congressionally-authorized Employee Retention Credit (ERC), a valuable relief program created during the pandemic to support businesses who...more

Foley Hoag LLP

Recent Updates on the Applicability of IRC Section 280E to Cannabis Companies

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Cannabis companies are increasingly taking non-280E positions on their current year federal income tax returns, while many, such as public “MSOs,” have amended prior years’ returns to reflect this position. Foley Hoag’s Tax...more

Fox Rothschild LLP

Auditor Releases “Snapshot” of IRS Workforce Revealing Devastating Extent of Initial Job Cuts

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The Treasury Department’s Inspector General for Tax Administration (TIGTA) has released a report showing how the Internal Revenue Service has been dramatically impacted by government-wide efforts to reduce the size of the...more

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