Having spent the last two years creating and building the Office of Fraud Enforcement, appointing and staffing National Fraud Counsel, and instituting and expanding the Office of Promoter Investigations, and with billions of dollars in funding on the horizon, the IRS is poised to launch an unprecedented era of enforcement. With new personnel, enhanced training, heightened internal cooperation among operating divisions, expanded information reporting for “digital assets” and ongoing collaboration with federal agencies and treaty partners, we anticipate increased fraud referrals, new compliance campaigns, and more parallel proceedings targeting taxpayers participating in abusive tax avoidance schemes and their professional enablers. Meanwhile, standards for judicial review of regulations and other guidance continue to evolve, opening new paths for taxpayers to challenge IRS enforcement actions. This panel will discuss what to expect in 2022 including, but not limited to, a continued focus on high income non-filers, high wealth taxpayers engaged in abusive transactions, cryptocurrency reporting and enforcement, foreign reporting obligations, residency incentive programs, Maltese pension plans, inflated business credits, and monetized installment sales.

Speakers: Caroline Ciraolo, Michael Desmond, Nathan Hochman & Steven Toscher

CE Credit: 1.5 hrs