IRS Will Oppose Privilege Claims Where Accountant Is Hired by Lawyer, Official Says

The government is likely to oppose claims of privilege for accountants who have been hired by lawyers representing clients in tax cases, a senior Internal Revenue Service criminal attorney said May 6…

KPMG Practitioners Discuss IRS Audit Dispute Resolution Strategies, New IRS Procedures

Members of KPMG’s tax controversy services practice, in a May 5 webcast, provided resolution strategies that taxpayers need to consider when the taxpayers and the Internal Revenue Service…

IRS Looking at Buy-In Issue Surrounding Cost-Sharing Arrangements, Official Says

The Internal Revenue Service is “affirmatively looking” at the buy-in issue for cost-sharing arrangements in the transfer pricing context, Large and…

IRS Corporate Audits Declining, Research Group Says; Agency Disagrees with Analysis

The Internal Revenue Service’s audit efforts aimed at the nation’s largest corporate taxpayers have declined since 2005 and are now “at an all-time low,” according to…

IRS Offers Its Agents Road Map for Auditing Distressed Asset Trust Tax Shelter Deals

The Internal Revenue Service March 24 gave its agents a detailed road map for auditing distressed asset trust (DAT) tax shelters, deals in which taxpayers use trusts to shift built-in losses from a tax-indifferent party to a U.S. taxpayer who has not incurred an economic loss.

IRS Focused on Global Issues, Greater Cooperation, Transparency, Former Deputy Commissioner Says

Taxpayers can expect a sharp focus on global issues at the Internal Revenue Service going forward, marked by closer relationships with other taxing authorities, an…

BNA INTERVIEW: International Tax Landscape Shaped by Globalization, Shifting Economy, Ex-IRS Official Says

Deborah Nolan, former commissioner of IRS’s Large and Mid-Size Business Division and currently with Ernst & Young LLP, tells BNA that…

U.S. Crafting Protocol for Joint Audits With Treaty Partners, Shulman Says

Commissioner of Internal Revenue Douglas Shulman Dec. 10 said the United States is in the early stages of crafting a protocol that would allow it to conduct joint audits with other treaty partners, an effort that he said could include issues that now are worked out by competent authorities…

IRS Voluntary Disclosure Program Poses Threat To Foreign Banks

It is a tried-and-true prosecutorial strategy that makes up in effectiveness what it lacks in subtlety—prosecute a lesser party to a criminal matter and induce his or her cooperation against the major players by threatening a lengthy prison sentence if he or she does not cooperate and leniency if he or she does.