On July 21, 2021, Caroline D. Ciraolo presents “The IRS is Focused on Enforcement – What You Need to Know” for the 2021 CBIZ Virtual Tax Conference.
Description: In March 2020, the IRS formed the Office of Fraud Enforcement and appointed a former IRS Special Agent in Charge and Director of International Operations to lead its development. Since then, the IRS has appointed a National Fraud Counsel, enhanced fraud training efforts across the IRS operating divisions, reinforced fraud referral procedures with subject matter experts, published new compliance campaigns, and initiated civil examinations and criminal investigations of taxpayers participating in, and promoters of, abusive tax avoidance schemes. In April 2021, the IRS established the Office of Promoter Investigations to focus on priority areas including, but not limited to, micro-captive insurance, syndicated conservation easements, and Puerto Rico residency programs. While these transactions can be the subject of abuse, they are not inherently improper and practitioners need to be prepared to defend reasonable positions. This session will discuss the current state of enforcement, recent developments and litigation, defenses being raised, and what we can expect in the days to come.