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Enforcement › Tax Returns

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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?

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

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

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

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If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Allen Barron, Inc.

What is the “Abusive Use of Partnerships” and Why does the IRS Care?

Allen Barron, Inc. on

What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more

Fox Rothschild LLP

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

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The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

DarrowEverett LLP

The Brass Tacks: IRS Creates Process for Withdrawing ERC Claims

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The Internal Revenue Service (“IRS”) recently granted employers a means to avoid interest and penalties on inappropriately taken Employee Retention Tax Credit (“ERC”) claims. This surely will come as a relief to taxpayers who...more

Alston & Bird

IRS Prioritizes Enforcement Against High-Wealth Taxpayers in the Inflation Reduction Act Strategic Operating Plan

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The Inflation Reduction Act Strategic Operating Plan, released last week by the Internal Revenue Service, envisions a future of increased audits and penalties for family offices, high-wealth individuals, large partnerships,...more

White and Williams LLP

2022 Tax Filing Season: Nine Things You Need to Know

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The 2022 tax season is upon us. With what promises to be an unusual tax filing season, below are nine updates and tips to keep in mind. 1. Tax Returns are Lagging. On January 12, the National Taxpayer Advocate issued its...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Latest Swiss Cross-Border Tax Investigation Reflects Wider US Enforcement Agenda"

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Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid...more

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