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Handling The IRS Audit

In Audit, IRS Regulations by Larry Jones2 Comments

            A. The following items should be discussed with the Revenue Agent at the first meeting: Meet with the Revenue Agent to present the power of attorney form and to establish the ground rules for the audit. Place for the audit. Interview of the client. Submission of document request by the Revenue Agent for documents …

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IRS Tax Penalties on the Rise, Particularly Employment Tax Penalties

In Audit, Employment Tax, Penalties, Trust Fund Penalty by Jason Freeman1 Comment

The IRS recently issued its annual Data Book, providing a glimpse into the world of tax administration during the past fiscal year.  The recent release provides a number of interesting takeaways, but here are a few of the highlights: The IRS assessed $27.3 billion in civil penalties during FY 2016. The IRS assessed close to $12.5 billion in additional taxes …

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An Update on International Tax Enforcement

In Audit, International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

International tax enforcement remains one of the nation’s top tax priorities. Indeed, a number of important developments over the past year signal that offshore enforcement issues remain firmly in the government’s crosshairs. Notably, the past year saw the Treasury Department implement several key regulations that impose new reporting obligations and that are designed to increase transparency and promote its ability …

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The Evolution of Partnerships and Partnership Audits

In Audit, Partnership Tax by Jason FreemanLeave a Comment

Major changes are on the way for the partnership tax audit rules.  The Bipartisan Budget Act of 2015 (the “BBA”), which will apply “to returns filed for partnership taxable years beginning after December 31, 2017,” is replacing the existing partnership audit framework with a new “streamlined” audit regime that is designed to allow the IRS to more easily audit partnerships.  …

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IRS Adding 700 Enforcement Personnel and Criminal Agents—Audits and Enforcement Activities to Increase

In Audit by Jason FreemanLeave a Comment

The IRS is now well into its initiative to add 700 audit and enforcement personnel, in what IRS Commissioner Koskinen recently called the Service’s “first significant enforcement hiring in more than five years.” The new hires are designed to fill key gaps in the IRS’s enforcement workforce that have been created by years of attribution, largely due to budget cuts …