On October 22, 2021, Caroline D. Ciraolo presents “The IRS is Focused on Enforcement – What You Need to Know to Navigate Troubled Waters” for the Annual Meeting of the National Association of State Bar Tax Sections in Nashville, TN.

Description: In March 2020, the IRS formed the Office of Fraud Enforcement and appointed a former IRS Criminal Investigation Special Agent in Charge and Director of International Operations to lead its development. Since then, the IRS has appointed a National Fraud Counsel, enhanced fraud training efforts across the IRS operating divisions, reinforced fraud referral procedures with subject matter experts, announced new compliance campaigns, and initiated parallel proceedings targeting taxpayers and professional enablers participating in abusive tax avoidance schemes.  In April 2021, the IRS established the Office of Promoter Investigations and appointed as its Acting Director a veteran of the IRS with extensive experience managing investigations and examinations involving abusive transactions. Priority areas include, but are not limited to, micro-captive insurance, syndicated conservation easements, and Puerto Rico residency programs. While these transactions can be the subject of abuse, they are not inherently improper and practitioners need to be prepared to defend reasonable positions. This session discusses the current state of enforcement, recent developments, and what we can expect in the days to come.