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IRS Initiates Special Pass-Through Entity for High-Income Compliance, Forms Dedicated Workgroup for Complex Partnerships and More

    Published September 23, 2023 – The Internal Revenue Service, or IRS for short, is the government agency in charge of collecting taxes in the United States. Recently, the IRS has been paying a lot of attention to people who earn a lot of money and businesses that operate as pass-through entities. In this article, we will break down what this means and why it’s important for everyone.

    Table of contents

    Creation of Pass-Through Work Group


    First, let’s talk about high-income compliance. High-income individuals are those who earn a lot of money, usually in the hundreds of thousands or even millions of dollars per year. The IRS wants to make sure that these people are paying their fair share of taxes. They do this by closely examining their tax returns and financial information. This helps ensure that everyone is following the rules and paying the right amount of taxes.

    Now, let’s shift our focus to pass-through entities. Pass-through entities are a type of business structure where the profits and losses “pass through” to the owners’ individual tax returns. This includes businesses like partnerships, S corporations, and sole proprietorships. The IRS is interested in these businesses because they want to make sure they are reporting their income correctly and paying the right amount of taxes as well.

    To tackle these issues, the IRS has set up a new unit called the Pass-Through Entity Unit. This unit is dedicated to examining pass-through entities more closely. They look at things like how income is distributed among the owners and whether the business is following tax laws correctly.

    So, why does all of this matter? It matters because taxes fund important government services like schools, roads, and healthcare. When high-income individuals and pass-through entities don’t pay their fair share, it can put a strain on these services. By focusing on high-income compliance and the new Pass-Through Entity Unit, the IRS is working to make sure everyone pays their fair share and keeps these essential services running smoothly.


    A. Overview of the IRS’s Transformation Efforts and the Need for Enhanced Enforcement

    The IRS, short for the Internal Revenue Service, is like the tax sheriff of the United States. They collect the money needed to keep our government running, but sometimes, people and businesses don’t pay what they owe. To make sure everyone follows the rules, the IRS is working on some big changes. These changes are like giving the sheriff a new badge and a faster horse.

    B. The Significance of High-Income Earners, Partnerships, Large Corporations, and Tax Law Abusers

    The IRS is especially interested in folks who earn a lot of money, big business partnerships, and large companies. Why? Because they can make a big difference when it comes to tax dollars. If they don’t pay their fair share, it can affect the money available for schools, roads, and other important stuff. Some people try to bend or break the tax rules, and the IRS wants to stop them, like a referee in a game making sure everyone plays fair.

    C. Introduction to Pass-Through Entities and Their Role in Taxation

    Now, let’s talk about something called pass-through entities. These are like special kinds of businesses where the money they make “passes through” to the owners’ personal tax bills. It’s kind of like when friends share a pizza, and each friend pays for their slices separately. Pass-through entities include businesses like small partnerships, one-person shops, and some big companies too. They’re important because they affect how much money the government gets.

    D. Explanation of Pass-Through Entity Taxation and Its Complexity

    Imagine you have a lemonade stand with your friends. You make money selling lemonade, but you and your friends each have to pay taxes on your lemonade earnings when tax time comes around. Pass-through entities work a bit like that. The money they make doesn’t get taxed at the business level; instead, it’s the owners who pay taxes on their share of the profits.

    But here’s the tricky part: figuring out how much each owner owes in taxes can be like solving a puzzle. It depends on how the profits are divided and the tax laws in place. Sometimes, it can get pretty complicated, like trying to solve a really hard crossword. That’s why the IRS wants to make sure pass-through entities are doing their tax math correctly and not making mistakes or bending the rules.

    The Creation of the Pass-Through Entity Work Group

    A. Explanation of the New Pass-Through Area within LB&I

    Inside the IRS, there’s a part called the Large Business and International Division, or LB&I for short. They deal with the big players, like large businesses and wealthy folks. LB&I is like the special team within the IRS, and they’ve decided to make a new part of their team just for pass-through entities. It’s a bit like a sports team adding a new position because they realize they need someone to cover a specific area of the game.

    B. Announcement by LB&I Commissioner Holly Paz

    Imagine your team’s coach calling a team meeting to introduce a new player. In this case, LB&I Commissioner Holly Paz made an announcement to tell everyone about the new pass-through team. She’s like the head coach, and she explained why this new team is important. It’s a bit like a team captain giving a speech about why they need a new player on the field.

    C. Objectives and Goals of the Pass-Through Work Group

    Every team has a game plan and goals they want to achieve. The pass-through work group is no different. They have specific things they want to do. For example, they want to make sure pass-through entities pay the right amount of taxes and follow the rules. Think of it as a soccer team aiming to score goals and defend their own net. The pass-through work group has their goals too, and they’re like the referees, making sure everyone plays by the rules.

    D. Expected Timeline for the Formal Establishment of the Work Group

    When a new player joins a sports team, it takes some time for them to get their jersey and start playing in games. The pass-through work group is a bit like that new player. They’re still getting ready to play their part. The timeline for when they’ll be fully set up and working is like waiting for that new player to get on the field. It might take a bit, but once they’re in the game, they’ll help make sure everything runs smoothly.

    Strategies and Funding

    A. Utilization of Inflation Reduction Act Funding to Support the New Initiative

    To make their new pass-through team work effectively, the IRS needs money. They’ve found some help from something called the Inflation Reduction Act. It’s like finding extra cash in your piggy bank to buy something you really need. The IRS is using this money to make sure the pass-through work group has what they need to do their job well.

    B. Disruption of Tax Evasion by Large Partnerships Using Pass-Through Entities

    Imagine some people trying to sneak into a movie without buying tickets. That’s a bit like what some large partnerships do with taxes. They try to avoid paying their fair share by using pass-through entities. The pass-through work group is like the ushers at the movie theater. They’re here to stop tax evasion and make sure everyone pays their way.

    C. Alignment of Efforts with IRS’s Broader Commitment to Ending Historically Low Error Rates

    The IRS wants to get better at what they do. They don’t want to make mistakes when it comes to taxes. Historically, they’ve made some errors, but they’re working hard to fix that. It’s like a student who wants to improve their grades in school. The pass-through work group is part of this effort. They’re like the tutors helping the student get better.

    D. Coordination with the National Treasury Employees Union (NTEU)

    When you’re working on a big project, it helps to have friends who support you. The IRS has a friend called the National Treasury Employees Union (NTEU). They work together like teammates on the same soccer team. The NTEU helps make sure the pass-through work group has what they need and that everyone is working together smoothly.

    The Larger Compliance Effort

    A. Overview of the Comprehensive Compliance Initiative

    The IRS is like a busy detective agency, and they want to make sure everyone is following the tax rules. They’ve launched something called the Comprehensive Compliance Initiative, which is like a big plan to catch those who aren’t playing by the tax rules. Think of it as the detectives putting on their best gear to solve a big case.

    B. Focus on High-Income and High-Wealth Individuals, Partnerships, and Large Corporations

    In their quest to make sure everyone pays their fair share, the IRS is keeping a close eye on the people and businesses who earn and have a lot of money. This includes rich individuals, big business partnerships, and large companies. It’s like the IRS is watching over the players who have a lot of points in a game, making sure they’re not cheating.

    C. Decline in Audit Rates Over the Past Decade and the Need for Enhanced Enforcement

    Over the last ten years or so, the number of tax audits (like financial check-ups) has gone down. But that doesn’t mean everyone is following the rules. It’s a bit like people speeding on the highway when there aren’t enough traffic cops around. The IRS realizes they need to do more to enforce the rules, like adding more traffic cops to catch the speeders.

    D. Incorporation of Technology and Artificial Intelligence to Improve Compliance Detection

    Imagine detectives using fancy gadgets to solve mysteries. The IRS is doing something similar by using technology and Artificial Intelligence (AI) to catch tax rule breakers. It’s like having super-smart helpers who can spot things humans might miss. This way, they can find those who aren’t following the rules faster and more accurately.