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Following their recent announcement regarding new partnership and global high wealth enforcement initiatives, the Internal Revenue Service (IRS) on Oct. 20 announced another enforcement initiative focusing on foreign corporations and the largest corporate taxpayers.
For decades, large corporate taxpayers under continuous audit have been able to make disclosures under Revenue Procedure 94-69 at the beginning of an examination to notify the Internal...
The IRS Independent Office of Appeals (“IRS Appeals”) was established to provide an “independent” IRS function that is separate and independent from the IRS’s compliance functions that...
The IRS Independent Office of Appeals ("IRS Appeals") was established to provide an "independent" IRS function that is separate and independent from the...