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"Emerging Issues in Tax Compliance After IRS Funding Increase”

May 8, 2023

Tom Cullinan and Juan Vasquez, Jr.'s article, "Emerging Issues in Tax Compliance After IRS Funding Increase,” in Tax Notes Federal

Tax Notes

In a May 8, 2023, Tax Notes Federal article, Atlanta-based Shareholder Tom Cullinan and Houston-based Shareholder and Tax Controversy Chair Juan Vasquez, Jr. predict how the IRS will use the influx of funding from the Inflation Reduction Act to pursue specific enforcement-related initiatives including:

  • The employee retention credit;
  • Malta Pension Plans;
  • Monetized Installment Sales;
  • Certain CRAT transactions.

They also offer suggestions for those taxpayers that may get caught up in what could be coming.

“We focus on the emerging issues initiative because the IRS appears better positioned to make quick inroads in that space than it is for some of the plan’s other enforcement-related initiatives,” the article explains.

Cullinan and Vasquez, Jr. further outline the four key projects associated with the emerging issues initiatives:

  1. Mobilize resources to focus on high-risk and emerging issues that have not received appropriate enforcement attention.
  2. Improve, expedite and scale detection of emerging issues, including building stronger feedback processes from all parts of the IRS.
  3. Establish processes to respond more rapidly to emerging issues and develop treatments that can be deployed quickly and integrated into enforcement efforts.
  4. Hire, onboard and train the staff needed to achieve appropriate compliance coverage rates.

“All in all, the IRS is well armed with its additional funding to absolutely ramp up enforcement efforts in the areas that need to be targeted to promote effective tax administration,” said Cullinan and Vasquez, Jr.

To learn more, subscribers may view the full article here.