Internal Revenue Service/Department of Justice (Tax Division) Enforcement Priorities
Originally published in the Michigan Business Law Journal:
I recently attended the 30th Annual National Institute on Criminal Tax Fraud and the Third Annual National Institute on Tax Controversy sponsored by the American Bar Association. What makes this seminar particularly important and informative to business lawyers is that the key speakers are the leading tax enforcement officials from the U.S. Department of Justice—Tax Division (“Justice”), the U.S. Department of the Treasury (“Treasury”), and the Internal Revenue Service (IRS). In other words, what these people say matters.
This column will be the first of two outlining government enforcement priorities and, as such, practice tips that may benefit your clients. Forewarned is forearmed. Before I delve into particulars, my general take-away is that the government has done a remarkable job of leveraging technology and marshalling resources with the same or even less personnel than several years ago. The Treasury and Justice departments know where information about businesses and individuals is located, and they know how to access that information. The coordination between the two departments is at historic dimensions. Taxpayers and their representatives would be wise to take note.
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