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.
Contacts
Insights
Client Alert | 3 min read | 03.24.26
California Considering A Massive Expansion of Its Antitrust Laws
Legislative efforts to significantly expand California’s antitrust laws are working their way through the state legislature. The most comprehensive overhaul is Assembly Bill 1776 — the Competition and Opportunity in Markets for a Prosperous, Equitable and Transparent Economy (COMPETE) Act, introduced by Assembly Majority Leader Cecilia Aguiar-Curry, on March 23, 2026. AB 1776 is modeled closely after draft legislation recommended by the California Law Revision Commission (CLRC) in December. AB 1776 would not only significantly expand potential liability for single-firm conduct and monopolization but would also explicitly decouple California antitrust analysis from certain federal standards. Companies doing business in California should pay close attention to AB 1776 because of its potentially dramatic impact, including increased exposure to antitrust litigation and increased compliance costs.
Client Alert | 2 min read | 03.23.26
Client Alert | 1 min read | 03.23.26
Client Alert | 7 min read | 03.23.26




