The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. 1 Specifically, the ...
Tax controversy is a term that describes disputes between taxpayers and taxing authorities, most commonly the Internal Revenue Service (IRS), regarding the amount of tax owed or the application of tax ...
The IRS has announced a series of procedural changes this year intended to streamline the audit and issue resolution process for large and international businesses. The changes will make it easier for ...
Starting October 1, 2025, the IRS launched a two-year pilot program that could save taxpayers significant time and money in resolving tax disputes. The enhanced Post Appeals Mediation (PAM) program ...
The IRS is operating with at least 25% fewer employees than a year ago, and, as of mid-December 2025, nearly two-thirds of senior leadership positions remained vacant or filled with acting managers, ...
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