In recent posts, including my December 2017 article on OVDP Withdrawals and Rejections, I have described several of the issue-specific “compliance campaigns” launched by the Large Business and International (LB&I) division of the IRS in 2017. One of those campaigns focuses on abuse of the rules governing the creation of captive insurance companies. What Are Read more about LB&I’s Micro-Captive Insurance Campaign: Illegitimate Insurance Carries Huge Risk of IRS Scrutiny[…]

Conservation and preservation easements offer taxpayers some of the largest charitable contribution deductions to be had under the U.S. tax code, which is extraordinary when one considers that no property actually changes hands under such an agreement. Rather, the owner of the land, building, or art collection in question maintains his or her ownership but Read more about How Conservation and Preservation Easements Offer Huge Tax Benefits[…]

In a recent article on Deducting S Corporation Losses in Excess of Basis, I explained that the Large Business and International (LB&I) division of the IRS signaled a shift in enforcement tactics with its 2017 announcement of 13 issue-specific “compliance campaigns.” Eleven additional campaigns were launched in November 2017, suggesting that the initial 13 are Read more about The LB&I OVDP Declines and Withdrawals Campaign: An IRS Enforcement Initiative With Known Targets[…]

As I described in a previous post on Deducting S Corporation Losses in Excess of Basis, the IRS announced a shift in 2017 toward issue-specific enforcement practices for its Large Business and International (LB&I) division, built around 13 initial “compliance campaigns.” One of those campaigns centers on Form 1120-F, which many foreign business entities conducting Read more about Filing Your IRS Form 1120-F: Announcing Yourself Is Better Than Disqualifying Yourself[…]

In February of 2017, the IRS announced a major shift in enforcement methods for its Large Business and International (LB&I) division, with the revamped approach centering on issue-specific “campaigns.” The initial 13 campaigns are already underway. In past years, the enforcement activities of the LB&I have predominantly consisted of audits of the largest corporations, with Read more about Deducting S Corporation Losses in Excess of Basis[…]