One of the risks in eggshell civil audits -- where risk of criminal prosecution is material -- is the possibility of parallel investigations. Parallel investigations are simultaneous civil investigations and criminal investigations. These can involve... Read More
In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large... Read More
Readers interested in the risks of being audited with respect to income tax noncompliance arising from foreign assets (particularly financial accounts) often ask what it takes for the IRS to prove fraud. I am aware of no standard litmus test of civil... Read More