Tag: tax audit

By Anthony Diosdi In August of 2020, the Internal Revenue Service (“IRS”) launched a compliance campaign that targets the individual compliance with the Section 965 transition tax through examinations and correspondences. In October of 2020, the IRS announced it will be expanding Section 965 examinations. Our experience with Section 965 audits indicates that the IRS is focusing on the earnings and profits (“E&P”) calculations, the calculation of foreign tax credits, foreign tax pools, and transactions used to reduce E&P. It has also been our experience that a significant number of CFC shareholders facing a transition tax audit could greatly benefit by making a late 962 election. This article discusses the 965 transition tax and the possibility of making a 962 election. A Section 962 election could be a very useful…

Unless you are receiving a refund or stimulus payment, no one wants to receive communications from the IRS. In many cases, such unexpected letters include notices of an audit for either your personal or business taxes. Some audits are random and could never be predicted, while others are triggered by discrepancies or suspected inaccuracies on your tax returns. If you receive notice of an audit, the coming weeks can be inconvenient, as you will need to gather a significant amount of information. It can be tempting to ignore the notice and hope the issue disappears, though it will not disappear, and failing to address and handle an audit properly can have serious consequences. You should contact an experienced tax audit attorney in San Francisco as soon as you learn about…