How IRS Attorney Departures Will Prolong Cases, Spur Settlements
Big job cuts and reductions in resources at the IRS are liable to prolong disputes over tax bills and force the agency to leave money on the table when cases are finally resolved.
More than 170 attorneys have withdrawn from representing the IRS in cases in US Tax Court since Donald Trump became president in January, according to a Bloomberg Tax analysis. Many have quit the IRS altogether amid a major exodus of employees. Some Justice Department attorneys who represented the IRS in tax disputes in federal appeals courts have also left, moves that could impact some of the biggest, most prominent tax-related cases in the courts.
The diminished resources suggest it’ll take longer to resolve cases, former attorneys and former IRS and DOJ officials say. The IRS may also be pushed into considering settlements in some cases where perhaps it wouldn’t otherwise. That would mean settling cases on less favorable terms for the agency, and potentially give taxpayers a leg up in dealing with the IRS.
In this episode of Talking Tax, Bloomberg Tax senior reporter Michael Rapoport discusses the attorney departures and their implications, as well as attorneys’ frustrations about their jobs and fears about the future that prompted some to leave the IRS.
Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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12:41
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12:41
Companies Face Tariff-Induced Transfer Pricing Audit Risks
President Donald Trump's widespread tariffs are boosting tax dispute risks for companies that are scrambling to understand how to factor the new trade duties into their transfer pricing and tax planning without attracting an audit.
Tariffs raise the prices of imported goods, meaning companies importing products from their own affiliates may have to—or want to—adjust the pricing of those transactions to meet transfer pricing rules that require them to treat the deals as though they were done at arm's length, with unrelated parties.
The added cost of the tariff will likely knock the pricing for many goods out of that arm's-length range, so companies may have to adjust these prices to stay compliant. Additionally, companies may be able to make adjustments to mitigate the tariff impacts by reducing the price the US entity pays for the good.
These adjustments can attract scrutiny, however, from both tax and customs agencies. And growing geopolitical tensions may make it hard for companies to rely on tax dispute resolution mechanisms like mutual agreement procedures.
In this episode of the Talking Tax Podcast, Crowe LLP transfer pricing practice leader Sowmya Varadharajan talked with reporter Caleb Harshberger about the choices, and risks, companies are facing.
Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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12:34
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12:34
Enrolled Agents Anticipate IRS Chaos for Next Tax Filing Season
Tax preparers consider themselves foot soldiers on the front lines of Americans' income tax preparations.
They provide advice and file the returns, helping the government collect its revenue and make sure people are paying their fair share. They are also some of the first to warn taxpayers about scams. This group of preparers includes enrolled agents, who are the only federally licensed tax practitioners.
Enrolled agents now are assessing what the recent exodus of thousands of IRS workers and agency leadership means for filing season. They're also watching for guidance for how to implement new policies from the massive 2025 GOP tax law.
Bloomberg Tax’s Erin Slowey spoke with Jennifer MacMillan, president of the National Association of Enrolled Agents, about rules related to overtime and tips from that new tax law, the regulation of tax preparers, and what happens next at the IRS as its workforce has been slashed.
Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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11:54
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11:54
Congressional Deadline on Shutdown Deal Adds to IRS Challenges
Congress is back in session with just a few weeks to reach an agreement before government funding runs out Sept. 30. For IRS watchers, the lack of agreement on how to fund the tax collection agency or whether to extend expiring tax breaks rank among the key issues lawmakers will grapple with over the coming months.
In this week’s episode of Talking Tax, Bloomberg Tax reporter Zach C. Cohen and Bloomberg Government reporter Maeve Sheehey preview the government funding fight and potential movement on budget reconciliation bills, and the impact on tax policy and administration.
Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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12:27
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12:27
IP Poses Risks, Opportunities for Companies' Tariff Planning
As President Donald Trump's tariffs make waves in the world economy, multinational companies are mulling what it could mean for their intangible assets like intellectual property and brand recognition.
The vast majority of corporate value comes from intangibles. In 2020, such assets made up 90% of the value of the S&P 500, according to an often-cited study by IP consultant Ocean Tomo—up from up from just 17% in 1975.
Tariffs don’t directly levy fees on intangibles, but their value is often embedded into imported products, raising the tariffed price. These intangible assets can also come with a smorgasbord of options for companies to locate IP in countries to best blunt the impacts of tariffs or reduce taxes on their business.
On this episode of Talking Tax, Grant Thornton principal Glen Marku talked with reporter Caleb Harshberger about what companies' intangible assets could mean for their tariffs exposure and whether they need to rethink their tax planning.
Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
Talking Tax, from Bloomberg Tax, is a weekly discussion of the most pressing issues facing tax and accounting professionals. Each week the podcast features discussions with lawmakers, federal regulators, lawyers, and journalists. From the courts to Capitol Hill to the IRS, Talking Tax has it covered.
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