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Exam: IRS' Enhanced Enforcement Efforts for Partnerships and High-Net-Worth Individuals

Journal of Tax Practice & Procedure

In this article, George Hani of Miller & Chevalier, along with Matt Cooper of Deloitte LLP and Bryan Skarlatos of Kostelanetz LLP, write that the Internal Revenue Service (IRS) is ramping up enforcement efforts on partnerships and high-net-worth individuals, leveraging increased funding from the Inflation Reduction Act and new procedures under the Bipartisan Budget Act of 2015. The IRS Strategic Operating Plan underscores these efforts, which have led to structural changes and targeted initiatives. The authors review a number of key enforcement developments. They stress that the IRS is stepping up audits and enforcement, particularly for large partnerships and high-net-worth taxpayers, with stricter regulations, retroactive rule changes, and increased penalties for non-compliance. Hani, Cooper, and Skarlatos conclude businesses and individuals should prepare for heightened scrutiny and ensure tax compliance to avoid penalties.