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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
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
Speaking at a Practicing Law Institute program on April 25, Internal Revenue Service (IRS) lawyer Clifford Warren indicated that the IRS has been using the anti-abuse rule of Treasury Regulation Section 1.701-2 to scrutinize...more
The boost in funding for the Internal Revenue Service (IRS) provided in the Inflation Reduction Act of 2022 (IRA) comes just as it has started rolling out in earnest programs focusing on auditing complex partnership...more
The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more
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
Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more
The U.S. Supreme Court issued a unanimous opinion Thursday in United States v. Clarke (No. 13-301) addressing the standard that must be satisfied before a taxpayer can question Internal Revenue Service personnel about its...more
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