IRS Continues to Boost Enforcement Efforts with New Promotor Investigation Office
Client Alert | 1 min read | 04.26.21
The Internal Revenue Service (IRS) announced on April 19th the launch of the new Office of Promoter Investigations (OPI) aimed at enforcement against promoters of abusive tax transactions, such as syndicated conservation easements and micro-captive insurance schemes, and expanding on the work the promoter investigations coordinator has been pursuing for the past year. The new office is part of the IRS’s Small Business and Self-Employed Division (SB/SE) and will be led by acting director Lois Deitrich, an IRS exam official with over 20 years of experience. Although the office is housed within SB/SE, it will coordinate promoter investigations throughout all IRS business units, including Criminal Investigation and the Office of Fraud Enforcement.
The agency also recently announced a dedicated team of IRS Criminal Investigation employees working on “Operation Hidden Treasure,” focused on cryptocurrency and virtual currency tracking. Last year, the IRS added a new campaign led by the IRS’s “Wealth Squad” targeted towards audits of high net worth individuals and their related entities and the creation of a new Fraud Enforcement Office.
The establishment of the OPI comes on the heels of President Biden’s discretionary funding request for Fiscal Year 2022, which includes over $1 billion in proposed funding for the IRS to support increased tax enforcement focused on high-earning individuals and corporations. In addition, two House Democrats recently introduced bills to ramp up the IRS’s funding and mandate minimum audit levels for high-income individuals and corporations.
These efforts all seek to reduce the annual tax gap between what taxpayers owe and what they actually pay on time, which Commissioner Charles Rettig recently said could be over $1 trillion annually. Closing the tax gap through increased resources for IRS enforcement fits with President Biden’s campaign promise that corporations and high net worth individuals will “pay their fair share.” With these new offices and campaigns, and the large potential increase in funding, taxpayers should expect increase in audit activity and increased coordination between civil and criminal investigations.
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Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
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