How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...more
Effective March 12, 2025, the Georgia Department of Revenue (“GADOR”) issued Policy Bulletin IT-2025-01 implementing various updates to its Mandatory Film Tax Credit Audit Program....more
In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more
We have updated and republished this March 2024 blog post for a year-end summary. The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) Office of Field Operations is responsible for ensuring industry members comply with...more
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a “corporate jets”. This has been an intensifying area of focus by the IRS over the last few years as a result of recently-increased tax...more
Companies required to use “box 11” of Form W-2 in 2023 to report either payments of nonqualified deferred compensation (deferred compensation) or FICA taxation of unpaid deferred compensation may soon be challenged by...more
Even global icons like Beyoncé, among the wealthiest entertainers on the planet, are not immune to IRS scrutiny. Recently, Queen Bey found herself entangled in a dispute with the Internal Revenue Service (IRS) over an alleged...more
Last Friday, New York’s Governor Hochul delivered the following remarks at the annual meeting of the Business Council of New York State:“Someone asked me today, are we going to raise income taxes? I said, ‘I’m not raising...more
As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that...more
El 6/20/24, el IRS emitió el Consejo Fiscal 2024-59 para alertar a los contribuyentes que la mediación con el IRS puede ayudarlos a resolver sus problemas tributarios de manera temprana y efectiva. El IRS afirma que la...more
On 6/20/24, the IRS issued Tax Tip 2024-59 to alert taxpayers that mediation with the IRS can assist taxpayers to solve their tax issues early and effectively. IRS states that mediation with the IRS can be a more...more
Connelly v. Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as...more
You may have heard or even read about the U.S. Supreme Court’s recent decision regarding the date of death value of a deceased shareholder’s shares in a closely held corporation that owned a life insurance policy on the...more
It's astonishing how many business owners undervalue accounting and its profound financial impact on business operations, transactions, taxation, and profit. An effective accounting strategy captures the information required...more
When your business receives an audit engagement letter, don’t panic. While an audit may be time-consuming, costly, and invasive, having an experienced advocate on your side to navigate you through the process and represent...more
The Internal Revenue Service (“IRS”) released an update to its plan to transform agency work and improve taxpayer experience. The update to the Strategic Operating Plan provides “an outline of the major projects and outcomes...more
El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more
On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several times before, but this...more
The IRS announced a new campaign to audit high-net-worth taxpayers claiming business deductions for the use of private jets. Using some of the $80 million allocated for enhanced enforcement in the Inflation Reduction Act of...more
In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more
The Internal Revenue Service (IRS) has announced plans to initiate dozens of new audits this spring in an attempt to limit personal usage of corporate aircraft. These audits will focus primarily on “highest risk” corporations...more
The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more