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Enforcement › Corporate Taxes › Internal Revenue Service

Mayer Brown

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

Mayer Brown on

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

Fox Rothschild LLP

Millionaires, Corporate Jets and Crypto: IRS Unveils New Enforcement Initiatives

Fox Rothschild LLP on

Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more

Levenfeld Pearlstein, LLC

IRS’s Plan Includes Increased Audits for Corporate and High-Income Taxpayers

Levenfeld Pearlstein, LLC on

On April 6, 2023, the Internal Revenue Service released its much-anticipated strategic operating plan. The plan outlines how the agency will use the additional $80 billion in funding from the Inflation Reduction Act. Of...more

Davies Ward Phillips & Vineberg LLP

U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward

Davies Ward Phillips & Vineberg LLP on

The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more

Bailey & Glasser, LLP

BG Tax Alert - Take Two: Biden’s Budget Proposes Tax Hikes

Bailey & Glasser, LLP on

On March 28, 2022, President Biden announced his 2023 federal budget (Budget), which is often referred to as the President’s Green Book. While much of the Budget harkens back to the “Build Back Better Framework” (Framework),...more

Miller Canfield

The IRS's New Specificity Requirements for Research Credit Refund Claims – Possible Taxpayer Actions in Opposition

Miller Canfield on

On October 15, 2021, the IRS published Information Release 2021-203, based on Memorandum 20214101F (the "Memorandum") prepared by Field Attorneys in the Office of Chief Counsel, setting out a detailed procedure requiring...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides United States v. Clarke

Faegre Drinker Biddle & Reath LLP on

On June 19, 2014, the United States Supreme Court held that a taxpayer has the right to examine Internal Revenue Service (IRS) officials regarding their reasons for issuing a summons only if the taxpayer points to facts or...more

McDermott Will & Emery

IRS Revises Directive on IDR Issuance and Enforcement Process

McDermott Will & Emery on

On February 28, 2014, the Internal Revenue Service Large Business and International Division released updated guidance for examiners incorporating and superseding two directives relating to Information Document Requests. The...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Announces New IDR Enforcement Process"

Skadden, Arps, Slate, Meagher & Flom LLP on

On November 4, 2013, the Internal Revenue Service released an internal directive that completes a two-part process of reshaping the dynamic between taxpayers and IRS examiners during the information-gathering phase of an...more

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