The IRS's new unit to tackle pass-through entity tax-law enforcement could take years to stand up fully and for businesses to feel its impact in the form of tougher audits.

The push comes after years of concern among IRS officials that the agency lacked the expertise and resources to enforce laws around pass-through entities such as large partnerships, sparking fears some companies were manipulating the rules to pay less than they owed. But setting up and staffing up the new unit won't be easy.

On this episode of Talking Tax, Mary McNulty, a partner at Holland and Knight LLP, spoke to Bloomberg Tax about the purpose of the new unit and what it has to do to be successful.

"The wild card here is funding," she said. "So if Congress continues to cut the $80 billion of additional funding to the IRS and reduces the resources again to low levels then the IRS will lack the resources to carry out this strategic initiative, so time will tell.”

Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.