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.
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IRS Large Business & International Division Rolls Out 11 Additional Compliance Campaigns for Audits
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
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Tax Court Issues Opinion Striking Down Captive Insurance Arrangement
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
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IRS Issues Guidance to Examiners Handling BBA Partnership Audits
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
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IRS Audit Campaigns: What this means for taxpayers
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
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