Anecdotal Evidence that the IRS' Commitment to Auditing ERC is Not Mere Rhetoric... [ read ]
The IRS has been extremely vocal about its intensifying scrutiny of ERC claims, with IRS Commissioner Werfel declaring at yesterday's IRS Nationwide Tax Forum that the IRS is "increasing audit and investigative activities against…businesses filing dubious [ERC] claims." But is the Commissioner, as we like to question in Texas, "all hat and no cattle"? Anecdotally, the answer is definitely not.
An Unexpected IRS Enforcement Initiative: IRS Adds "Cost of Goods Sold" to Audit Compliance Campaign... [ read ]
The IRS is seemingly moving from the exotic back to plain vanilla, announcing a compliance campaign focused on taxpayers that may have inflated their reported cost of goods sold to reduce their taxable income.
Making a List and Checking it Twice: IRS Identifies Monetized Installment Sales as Listed Transactions... [ read ]
In proposed regulations released today, the IRS has identified monetized installment sales as listed transactions. You probably have questions – herein you will find some answers.
IRS Counsel Releases Legal Memorandum Regarding Suspension of Operations for the Employee Retention Credit... [ read ]
On July 21, IRS Chief Counsel released a Generic Legal Advice Memorandum (GLAM) regarding "Whether an Employer Experienced a Full or Partial Suspension of the Operation of a Trade or Business under Section 2301 of the Coronavirus Aid, Relief, and Economic Security Act or Section 3134 of the Internal Revenue Code due to a Supply Chain Disruption."
IRS Agents Getting Too Big For Their Britches... [ read ]
It appears Republicans on the Senate Finance Committee think that IRS agents are "getting too big for their britches." In a July 18 letter to IRS Commissioner Daniel Werfel the lawmakers asked for information about three separate allegations of IRS agent misconduct.
IRS Criminal Investigation Targeting Puerto Rico Act 20/22/60 Participants... [ read ]
On July 14th, the IRS released a thank you to the Inflation Reduction Act highlighting its improved service, plans for updating its technology and enforcement initiatives. The enforcement initiatives in the announcement focus on high-income filers including millionaires who don't pay their tax or have unfiled tax returns, and millionaires who are attempting to evade paying their taxes.
Chat GPT: IRS Friend, Foe, or Both?... [ read ]
Undoubtedly one of the hottest topics of 2023 has been ChatGPT and what role it can play, or should it play, in the workforce. Whatever your thoughts, precaution is an absolute necessity as it relates to tax and IRS matters.
IRS Criminal Investigation of Malta Pension Plan... [ read ]
Last week the IRS' interest in the Malta Pension Plan (MPP) took a very serious turn as IRS Criminal Investigators started contacting professionals and taxpayers who participated in MPPs. The first indication of IRS interest in MPPs was when MPPs were included on the 2021 IRS Dirty Dozen list.
IRS Badges of Fraud... [ read ]
On June 22nd, the U.S. Tax Court released a memorandum decision in Kamal v. Commissioner, T.C. Memo 2023-80, which is a helpful reminder of what evidence a court will consider when the IRS has proposed a 75% civil fraud penalty. In addition, Kamal is another example of the potential risks of filing a Tax Court petition.
How Long Does the IRS Have to Challenge an ERC Refund?... [ read ]
For employers who have either filed for or have received payment for Employee Retention Credit (ERC) claims, the significant surge in IRS examinations of ERC claims is similar to the shark in the movie Jaws. You know he is out there, but you don't know where he will bite and when.
