News & Analysis as of

Internal Revenue Service Enforcement Tax Avoidance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Morgan Lewis

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

Morgan Lewis on

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

BakerHostetler

IRS Enforcement Efforts in Puerto Rico Gaining Steam - Wave of Cases Expected

BakerHostetler on

Long-awaited enforcement actions may be coming soon for those who took advantage of the lucrative tax breaks offered by the Commonwealth of Puerto Rico without meeting the requirements. Prosecutions may also follow for...more

BakerHostetler

Cryptocurrency Tax Enforcement May Soon Reward Tipsters Through Whistleblower Program and False Claims Act

BakerHostetler on

Key Takeaways - ..Taxpayers could be criminally and civilly liable under state False Claims Act statutes for underreporting income linked to virtual currency. ..While the federal False Claims Act explicitly excludes tax...more

Morrison & Foerster LLP

The Impending Large Partnership Audits

In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more

Eversheds Sutherland (US) LLP

Warren bill fundamentally changes financial account reporting requirements and substantially increases IRS funding

On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more

Rivkin Radler LLP

Thinking About ‘Avoiding’ NY Tax Increases? Then Think About The False Claims Act

Rivkin Radler LLP on

According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more

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