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IRS to Hire 200 Attorneys to Combat Tax Schemes

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What You Need to Know

  • The positions will be available in more than 50 locations.
  • Abusive syndicated conservation easement deals and micro-captive insurance arrangements are two areas of focus.
  • New hires will help the IRS manage its increasing caseload in its multi-year effort to stamp out abusive schemes.

The Internal Revenue Service’s Office of Chief Counsel said Friday that it plans to hire up to 200 more attorneys to help the agency combat tax schemes.

IRS Commissioner Chuck Rettig said in a statement that “combating abusive tax transactions that threaten to undermine our tax system remains a top priority for our enforcement efforts.”

The IRS noted that “promoters have been particularly active developing and marketing tax shelter schemes that purportedly enable taxpayers to avoid paying what they legally owe.”

The new hires will help the IRS manage its “increasing caseload in its multi-year effort to stamp out these abusive schemes and ensure that those participating in them pay the tax they owe plus penalties,” the agency said.

The positions will be available in more than 50 locations, including Washington.

Those hired will provide legal advice to IRS professionals as they conduct audits of complex corporate and partnership issues and increasingly sophisticated and abusive transactions, the IRS explained.

New hires “will work in a variety of areas, including handling cases in the United States Tax Court, as well as serving on trial teams in our largest and most complex trials involving fact and expert witnesses, depositions and multi-week trials,” the IRS said.

They will also work with the Department of Justice Tax Division, which handles refund cases in district courts and the Court of Federal Claims.

Others hired will serve in the IRS national office with a focus on developing global regulatory solutions to the most sophisticated and abusive transactions and providing highly specialized advice to IRS litigation teams.

Abusive syndicated conservation easement deals remain a major focus for the IRS.

“These transactions generally use inflated appraisals of undeveloped land and partnerships devoid of legitimate business purpose designed to generate inflated and unwarranted tax deductions,” the IRS said.

Abusive micro-captive insurance arrangements are also on the IRS’ radar.

“These deals are generally sold to owners of closely held entities,” the IRS said. “The deals commonly lack many of the necessary attributes of insurance, have excessive premiums, insure highly improbable risks and have no connection to genuine business and insurance needs.”


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