{"id":4389,"date":"2022-12-14T22:46:00","date_gmt":"2022-12-14T22:46:00","guid":{"rendered":"https:\/\/patellawoffices.com\/blog\/?p=4389"},"modified":"2022-12-14T22:46:02","modified_gmt":"2022-12-14T22:46:02","slug":"what-i-learned-at-the-2022-national-institute-on-criminal-tax-fraud-and-tax-controversy-in-las-vegas","status":"publish","type":"post","link":"https:\/\/patellawoffices.com\/blog\/planning-for-tax-minimization\/what-i-learned-at-the-2022-national-institute-on-criminal-tax-fraud-and-tax-controversy-in-las-vegas\/","title":{"rendered":"What I learned at the 2022 National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas"},"content":{"rendered":"\n<p>I just returned from the\nAmerican Bar Association Section of Taxation\u2019s annual National Institute on\nCriminal Tax Fraud and Tax Controversy in Las Vegas, which is the largest gathering\nof criminal tax fraud and tax controversy attorneys in the nation.<\/p>\n\n\n\n<p>A major topic of discussion was the new $80 billion funding for the IRS, out of which $45 billion is dedicated for tax enforcement.\u00a0 Senior officials from the IRS made some interesting observations and statements.\u00a0 Below are some of my notes:<\/p>\n\n\n\n<p>\u2013\u00a0\u00a0\u00a0\u00a0\u00a0 The IRS is actively hiring personnel in all levels and positions, including auditors, criminal investigation agents, collection agents, etc. \u00a0Senior officials from the IRS solicited attendees, including many seasoned tax attorneys, to consider applying for jobs at the IRS.<\/p>\n\n\n\n<p>\u2013&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;\nThe IRS has started training new personnel with more frequency and size. For\nexample, the IRS just finished training 35 new criminal investigation special\nagents earlier this month. In 2023, the IRS expects to have far more trainings\nand larger classes than in recent history.&nbsp;\nAs a result, it is expected that more than 500 newly trained criminal\ninvestigation special agents will be onboarded over the next year. &nbsp;It is expected that civil agents (mostly\naccounting professionals) will be trained in even larger numbers.<\/p>\n\n\n\n<p>\u2013&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;\nThe IRS\u2019 audit rates in recent years\u2019 has been at an all-time low. &nbsp;For example, the audit rate for 2019 was\n0.4%.&nbsp; In 2023, with new personnel, the\nIRS expects to significantly increase its audit rates. <\/p>\n\n\n\n<p>\u2013&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;\nThe IRS has increased its IT budget by over 150%. &nbsp;As a result, the IRS plans to use artificial intelligence\nand data analytics to more intelligently identify noncompliance and new tax\ntargets. In addition, the data analytics will be used to minimize erroneous IRS\nnotices, which were common in recent years.<\/p>\n\n\n\n<p>In summary, the new $45 billion funding for the IRS enforcement will lead to more audit activity in the future.  However, due to training and onboarding of new personnel, it is expected that the new increased civil and criminal enforcement will take 1-2 years to see a noticeable heightened enforcement effect. In the meantime, taxpayers (and their advisors) should be aware that the 2022 tax year and onwards will be subjected to enhanced IRS scrutiny and increased examination.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>I just returned from the American Bar Association Section of Taxation\u2019s annual National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas, which is the largest gathering of criminal tax fraud and tax controversy attorneys in the nation. A major topic of discussion was the new $80 billion funding for the IRS, out [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_daextam_enable_autolinks":"1","_monsterinsights_skip_tracking":false,"_monsterinsights_sitenote_active":false,"_monsterinsights_sitenote_note":"","_monsterinsights_sitenote_category":0,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-4389","post","type-post","status-publish","format-standard","hentry","category-planning-for-tax-minimization"],"_links":{"self":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/4389","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/comments?post=4389"}],"version-history":[{"count":1,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/4389\/revisions"}],"predecessor-version":[{"id":4393,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/4389\/revisions\/4393"}],"wp:attachment":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/media?parent=4389"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/categories?post=4389"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/tags?post=4389"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}