Adding Bite to its Bark: IRS Announces Hiring of 3,700 to Audit Wealthy Taxpayers... [ read ]
IRS enforcement rhetoric is never a hollow threat. But given the IRS' limited resources historically, the saying "a barking dog seldom bites" sometimes held true. That is no longer the case, with the IRS announcing the opening of more than 3,700 positions to support its latest initiative to expand tax enforcement against high-income earners, partnerships, large corporations and promoters.
IRS Halts Processing of ERC Claims... [ read ]
On September 14, the IRS announced that it was immediately stopping processing of any new Employee Retention Credit (ERC) claims amid a surge in questionable claims. The moratorium on processing is effective immediately and will run through at least the end of the year.
IRS Announces Plans to Focus Examinations on High-Income Taxpayers, Partnerships, Corporations and Abusive Promoters With the Help of AI... [ read ]
On September 8th, the IRS, following a "top-to-bottom" review of enforcement efforts, announced that it will be shifting more enforcement efforts to "high-income earners, partnerships, large corporations and promoters abusing the nations' tax laws".
IRS Targets High-Income Individuals Illegally Claiming Puerto Rico's Tax Benefits... [ read ]
The Internal Revenue Service ("IRS") Commissioner Danny Werfel stated that the Agency is taking "swift and aggressive action" to strengthen enforcement efforts against high-income individuals. As part of these enforcement efforts, the IRS identified approximately 100 individuals, including crypto traders and fund managers suspected of illegally claiming Puerto Rico's tax benefits. According to the IRS, the enforcement efforts will include both civil audits and criminal investigations.
Auspicious or Ominous: IRS Increases Workforce by 14% in One Year... [ read ]
Within one year of its funding boost through the Inflation Reduction Act, the IRS has increased its workforce by nearly 11,000 workers, a 14% increase over 2022 staffing levels. Too fast too soon or just in time?
Another New IRS Audit Target: Employee Stock Ownership Plans (ESOPs)... [ read ]
In an August 9th announcement, the IRS said it has identified compliance issues for Employee Stock Ownership Plans (ESOPs). This is on the heels of recent IRS announcements regarding Malta Pension Plans, Puerto Rico Act 20/22/60 participants, Monetized Installment Sales, Cost of Goods Sold, and of course, Employee Retention Credits. According to IRS Commissioner Danny Werfel, "The IRS is focusing on this transaction as part of the effort to ensure our tax laws are applied fairly and high-income filers pay the taxes they owe.
Anecdotal Evidence that the IRS' Commitment to Auditing ERC is Not Mere Rhetoric... [ read ]
The IRS has been extremely vocal about its intensifying scrutiny of ERC claims, with IRS Commissioner Werfel declaring at yesterday's IRS Nationwide Tax Forum that the IRS is "increasing audit and investigative activities against…businesses filing dubious [ERC] claims." But is the Commissioner, as we like to question in Texas, "all hat and no cattle"? Anecdotally, the answer is definitely not.
An Unexpected IRS Enforcement Initiative: IRS Adds "Cost of Goods Sold" to Audit Compliance Campaign... [ read ]
The IRS is seemingly moving from the exotic back to plain vanilla, announcing a compliance campaign focused on taxpayers that may have inflated their reported cost of goods sold to reduce their taxable income.
Making a List and Checking it Twice: IRS Identifies Monetized Installment Sales as Listed Transactions... [ read ]
In proposed regulations released today, the IRS has identified monetized installment sales as listed transactions. You probably have questions – herein you will find some answers.
IRS Counsel Releases Legal Memorandum Regarding Suspension of Operations for the Employee Retention Credit... [ read ]
On July 21, IRS Chief Counsel released a Generic Legal Advice Memorandum (GLAM) regarding "Whether an Employer Experienced a Full or Partial Suspension of the Operation of a Trade or Business under Section 2301 of the Coronavirus Aid, Relief, and Economic Security Act or Section 3134 of the Internal Revenue Code due to a Supply Chain Disruption."
