A View from Meadows Collier

The IRS is undergoing significant workforce reductions, with thousands of employees leaving through layoffs, buyouts, and attrition. While some may welcome the idea of a smaller IRS, tax professionals should prepare for longer delays in audits, appeals, refund claims, and voluntary disclosure cases. In this episode of the Meadows Collier Podcast, Joel Crouch and Matt Roberts discuss how these staffing cuts will impact tax enforcement, compliance, and practitioner-client interactions.

With fewer personnel, the IRS is expected to lean more heavily on artificial intelligence and data analytics to select audits and enforce tax compliance, raising questions about the accuracy and fairness of AI-driven enforcement models. The episode also examines ongoing legal challenges to the Corporate Transparency Act, potential rollbacks in crypto tax reporting obligations, and the likelihood of a resurgence in aggressive tax shelters and questionable tax positions as enforcement capacity diminishes.

Tax attorneys, CPAs, and other professionals advising clients on IRS disputes, tax compliance, and federal reporting requirements will gain valuable insight into how these changes could reshape the tax landscape. Whether navigating delays in IRS interactions, shifts in voluntary disclosure policies, or evolving enforcement strategies, this discussion provides the critical updates needed to stay ahead of emerging challenges in tax administration.

In this episode of the Meadows Collier Podcast, attorneys Joel Crouch and Naveid Jahansouz provide an in-depth analysis of significant recent developments in tax law and IRS operations. They discuss the ripple effects of IRS staffing challenges, including hiring freezes, buyouts, and leadership departures, and what these changes mean for taxpayers and tax professionals. The episode also covers key tax court cases, such as the Langlois partnership basis case and the ongoing debate over 6038 penalties, along with potential tax legislation changes like TCJA extensions and IRS funding cuts. Joel and Naveid share valuable insights on navigating examinations, ensuring proper authorization in partnership filings, and staying compliant amidst shifting regulations. Additionally, the hosts examine high-profile cases like the Tom Goldstein tax indictment and the Dan Rada Swiss accounts case, providing practical takeaways for legal and tax practitioners. This comprehensive episode is essential listening for anyone wanting to stay informed and proactive in their tax strategy.

Join Joel Crouch, Mary Wood, and Jeff Glassman as they discuss what’s ahead for IRS enforcement in 2025. From cutting-edge technology and AI to changes in cryptocurrency reporting and high-net-worth audits, the team shares insights from the December 2024 ABA Tax Section Tax Fraud and Tax Controversy Conference in Las Vegas. This episode also covers key tips for audit preparedness, updates on the Employee Retention Credit, and strategies for navigating complex tax issues. Whether you're a business owner, tax professional, or just interested in the evolving tax landscape, this episode is packed with valuable information.

In this episode of our podcast, you will discover the latest trends in IRS criminal tax investigations, cryptocurrency compliance and voluntary disclosure programs with Joel Crouch and Mike Villa. This podcast will discuss some of the presentation highlights from the December 2024 American Bar Association (ABA) Criminal Tax Fraud Conference, such as funding, data analytics and areas of priority for the IRS. In addition, the evolution of the voluntary disclosure program continues to be a hot topic for the IRS and practitioners. The program has become increasingly formal, and practitioners feel that its usefulness is limited, and the penalties are too high. Practitioners are well advised to watch out for matters that are ripe for potential criminal tax investigations. We know employment taxes, fuel tax credits and ERCs are areas of interest for IRS criminal cases. Remember to consult with a tax attorney before being interviewed by the IRS.

In this episode of our podcast, A View from Meadows Collier, we are excited to share a special replay of the December 3, 2024 webinar titled, "Divisive Corporate Reorganizations: Threading the Eye of the I.R.C. § 355 Needle," featuring Firm Partner, Stephen A. Beck. In general, the distribution of appreciated assets from a corporation results in income tax liability to both the distributing corporation and the distributee shareholders. I.R.C. § 355, however, provides an exception through which a corporation can divide and distribute appreciated assets without triggering income tax liability to either the corporation or the shareholders. But qualifying under I.R.C. § 355 can be very difficult – like threading the eye of a needle. Mr. Beck discusses the many requirements that must be satisfied under I.R.C. § 355 to support deferral of taxable gain recognition, as well as potential pitfalls that could cause a divisive transaction to result in double taxation to the corporation and shareholder.

In this episode, firm lawyers Joel Crouch and Naveid Jahansouz delve into key recent developments in the tax landscape. They discuss noteworthy IRS procedural changes, including the revised penalty assessments for late-filed foreign gift forms, offering taxpayers more leniency with reasonable cause statements. They explore significant court cases like Ruby Tang v. Commissioner, where an IRS employee's unusual tax deductions led to a public trial, and Beyoncé Knowles-Carter v. Commissioner, which reveals that even celebrities aren't immune to tax disputes. The hosts also cover the IRS’s recent focus on pass-through entities and complex partnership audits, as well as the rising importance of compliance with the Corporate Transparency Act and evolving crypto regulations. This episode is packed with insider knowledge and practical insights, valuable for tax professionals and anyone keen to understand the latest in tax enforcement and policy changes.

In this episode, Firm Partner, Joel Crouch is joined by Firm Associate, Cody Gackle to explore the latest developments in tax law. They dive into the complexities of Employee Retention Credit (ERC) claims, discussing the IRS backlog, refund lawsuits, and how collection due process can intersect with ERC filings. Joel and Cody also share insights on recent cases, including Franco v. Commissioner, which examines the challenges of securing innocent spouse relief, and Schwartz, where a taxpayer successfully avoided penalties through reliance on a tax preparer.

The conversation extends to real estate professionals and passive losses in Warren v. Commissioner, highlighting the difficulties of qualifying for deductions while holding a full-time job. They also explore lien disputes, whistleblower claims, and key procedural issues, such as the importance of filing proper refund claims with powers of attorney. With humor and practical advice, Joel and Cody offer a candid look into the challenges taxpayers and advisors face, all while preparing listeners for Meadows Collier’s upcoming virtual firm conference on November 21st.

Tune in for a dynamic and informative discussion packed with real-world insights, case breakdowns, and actionable advice for navigating tax controversies.

In this episode of the Meadows Collier podcast, Joel Crouch and Brian Spiegel discuss recent tax developments, including updates from the U.S. Tax Court, alternative dispute resolution methods, and key estate tax cases. Brian shares insights from his experience clerking for U.S. Tax Court Judge Juan Vasquez, while both attorneys explore the Tax Court’s growing bench, ADR successes, and notable tax cases. They also touch on cryptocurrency taxation and changes to the IRS voluntary disclosure program, offering valuable insights for tax professionals and those interested in the latest IRS updates.

Listen to this podcast with Joel Crouch and Anthony Daddino, partners at Meadows Collier, as they discuss the complexities surrounding micro-captive insurance, particularly focusing on the IRS's increasing scrutiny and the implications for taxpayers. Other topics of the podcast include the IRS' settlement program and a potential shift in the IRS's approach. The challenges faced by taxpayers is emphasized in navigating these complexities and the importance of proper disclosure to mitigate penalties. The discussion continues with a look at the strategic decisions taxpayers may consider, including the choice between tax court and district court, and the potential for jury trials in tax cases. This podcast provides valuable insights into the evolving landscape of micro-captive insurance and the IRS's regulatory environment, encouraging taxpayers to stay informed and seek professional advice in this challenging area.

Listen to this podcast with Joel Crouch and Jeff Glassman, partners at Meadows Collier, for a summary of what has transpired to-date with regard to ERC claims, the questions that currently exist and thoughts as to what the IRS’ position will be in the future.