Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 20, 2026 – May 1, 2026. The agent was actively pursuing complex cases involving wealthy taxpayers and multinational structures, and his removal comes amid broader IRS workforce reductions and enforcement resource constraints.
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 20, 2026 – May 1, 2026.
The agent was actively pursuing complex cases involving wealthy taxpayers and multinational structures, and his removal comes amid broader IRS workforce reductions and enforcement resource constraints.
Counsel clarified that a "liberal" standard means the IRS should apply greater flexibility in evaluating reasonable cause, but taxpayers must still demonstrate good faith and reasonable cause to the...
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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 20, 2026 – May 1, 2026. The agent was actively pursuing complex cases involving wealthy taxpayers and multinational structures, and his removal comes amid broader IRS workforce reductions and enforcement resource constraints. Counsel clarified that a "liberal" standard means the IRS should apply greater flexibility in evaluating reasonable cause, but taxpayers must still demonstrate good faith and reasonable cause to the satisfaction of the secretary.
The IRS has reportedly begun the process of terminating a lead criminal investigation agent involved in probes of Malta pension structures and Puerto Rico's Act 60 tax incentives, raising concerns about the continuity of those enforcement efforts. The guidance explains that corporations with gross receipts of $20 million or less may be eligible if they meet specific criteria, including a lack of knowledge of the filing requirements, limited US presence, and prompt compliance once notified by the IRS.
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