The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
Continue Reading Conservation Easements: A Year End Review
Today the Internal Revenue Service’s Large Business and International division (LB&I) announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first
Continue Reading LB&I Announces Five More Compliance Campaigns, Bringing Total to 50 Campaigns
The Internal Revenue Service Large Business and International division (LB&I) has announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first
Continue Reading LB&I Announces Five More Compliance Campaigns
Earlier this week the Internal Revenue Service announced creation of a virtual currency compliance initiative that will focus on tax compliance by taxpayers engaging in virtual currency transactions. The IRS
Continue Reading IRS Announces Audit Campaign Focusing on Virtual Currency Transactions, But No Voluntary Disclosure Program to Address Non-Compliance
Yesterday the Internal Revenue Service’s Large Business and International Division announced that it was adding six more compliance campaigns to its previously-announced list of 29 such campaigns. The compliance campaigns
Continue Reading Internal Revenue Service’s LB&I Division Announces Six More Compliance Campaigns
On March 13, 2018, the Internal Revenue Service’s Large Business and International Division announced that it was adding five more compliance campaigns to its previously-announced list of 24 such campaigns.
Continue Reading Internal Revenue Service’s LB&I Division Unveils Five More Compliance Campaigns
On Friday, November 3, 2017, the IRS Large Business and International division (LB&I) announced the identification and selection of 11 additional compliance campaigns. In January 2017, LB&I unveiled its first
Continue Reading IRS Large Business & International Division Rolls Out 11 Additional Compliance Campaigns for Audits
The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from
Continue Reading Tax Court Issues Opinion Striking Down Captive Insurance Arrangement
As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships. As a result, beginning January 1, 2018, partnerships
Continue Reading IRS Issues Guidance to Examiners Handling BBA Partnership Audits
I was recently interviewed by the Wall Street Journal about the IRS LB&I audit campaigns discussed here. An interesting part of the conversation included a discussion of why the
Continue Reading IRS Audit Campaigns: What this means for taxpayers