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IRS Global High-Wealth Industry Group: Evaluation of an IRS Wealth Squad IDR

The IRS Large Business and International Division (LB&I), formerly known as the Large & Mid-Sized Business Division, recently formed a new Industry Group known as the Global High-Wealth Industry Group, commonly referred to as the “Wealth Squad.” The purpose of the Wealth Squad is to bring together an IRS team of specialists to coordinate the […] Read More…

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Basic Audit Techniques: Taxpayer Interviews

Requests to interview the taxpayer and return preparer during an otherwise normal IRS examination have become somewhat common. During an examination where the government is in possession of potentially incriminating evidence, such requests are routine. Near the inception of the recent IRS Voluntary Disclosure Program relating to previously undeclared foreign accounts, [i] the IRS examining […] Read More…

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IRS Audit Techniques Guides

Historically, Internal Revenue Service examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience […] Read More…

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IRS Voluntary Worker Classification Settlement Program

The IRS recently launched a new program designed to enable many employers to resolve past worker classification issues and achieve certainty by voluntarily reclassifying their workers on a prospective basis. The Voluntary Classification Settlement Program (VCSP)[i] is designed to allow eligible employers to obtain substantial relief from federal payroll taxes they may have owed for […] Read More…

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NEW 2012 IRS FBAR Voluntary Disclosure Initiative

For years, the IRS has been pursuing – with mixed success – the disclosure of information regarding undeclared interests of U.S. taxpayers (or those who ought to be U.S. taxpayers) in foreign financial accounts. On January 9, 2012, the IRS announced yet another offshore voluntary disclosure program (the 2012 OVDI) following on the success of […] Read More…

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Making a Voluntary Disclosure Under the 2011 OVDI

How to Make a Voluntary Disclosure Under the 2011 OVDI  The 2011 Offshore Voluntary Disclosure Initiative (OVDI) is offered to those taxpayers having interests in previously undisclosed interests in offshore financial accounts or assets. Frequently Asked Questions (FAQs) are available at  https://www.irs.gov/businesses/international/article/0,,id=235699,00.html Pre-Clearance: Taxpayers or representatives may fax to the IRS Criminal Investigation Lead Development […] Read More…

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Tax Penalty Relief – Reliance on Tax Advisor

The Internal Revenue Manual (IRM) contains a Penalty Handbook intended to serve as the foundation for addressing the administration of penalties by the IRS. It is the “one source of authority for the administration of penalties. . .”( Internal Revenue Manual (IRM) 20.1.1.1.1  (02-22-2008). Refer to IRM 9.1.3, Criminal Investigation – Criminal Statutory Provisions and Common […] Read More…

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Current IRS Enforcement Priorities

Current IRS Enforcement Priorities. The international arena will continue to test the enforcement resources of the IRS for years to come. There will be ongoing, enhanced coordination with treaty partners and international organizations (six of nine LMSB Tier 1 issues involve international components and LMSB Counsel lawyers have been trained in the fundamentals of international […] Read More…

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Introduction / Legal Disclaimer

Welcome to the Tax Litigation (Civil & Criminal) Report! This Report is intended solely for tax professionals to share and exchange general (non-client specific) thoughts and comments regarding recent developments, procedures, cases and authorities involving federal tax disputes and the representation of taxpayers before the Internal Revenue Service in examinations, tax collection matters, administrative Appeals, tax litigation, […] Read More…

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