New Jersey Of Counsel Gary Wells authored an article discussing the change within the IRS’ Large Business and International (LB&I) division away from enterprise-level examinations and to single issue audits or campaigns. The change in the IRS enforcement approach affects most large businesses (assets of at least $10 million) and taxpayers with international activities. The article titled, "IRS LB&I Campaigns: Filers Beware the Ides of March" was published on Monday, June 5, 2017 in Tax Notes.
In this article, Wells analyzes the application of the IRS’s future state initiative, a recently announced initiative to match the IRS' limited resources to its program goals and plan, focusing on how it will affect LB&I’s new campaign-style enforcement goals and initial 13 targets. Each of 13 current campaigns focuses on a single issue, like non-filing by international companies and industry issues. The article highlights the future difficulty that the IRS will encounter in implementing its altered enforcement regime and what hurdles taxpayers may face in defending their interests on the currently identified campaigns.
To read the article in full, please click here.
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Gary Wells concentrates his practice in the areas of business transactions, business taxation and international. To contact Gary directly: email: gwells@grsm.com and phone: (703) 303-7898.