IRS Claims “Big Business / Global Tax Evaders” New Focus – We’ll See

The Internal Revenue Service has announced that it would overhaul a unit devoted to scrutinizing large corporations and wealthy individuals,

a shift that would bolster the agency’s growing focus on international tax evasion.

The I.R.S. said that it would centralize operations at the core unit, which will now be known as the large business and international division,

The Internal Revenue Service has announced that it would overhaul a unit devoted to scrutinizing large corporations and wealthy individuals,

a shift that would bolster the agency’s growing focus on international tax evasion.

The I.R.S. said that it would centralize operations at the core unit, which will now be known as the large business and international division,

to give international examiners the authority to decide whether to pursue or settle contentious tax cases involving multinational corporations.

Larry R. Langdon, a former head of the large and midsize business division, said that

the latest shift underscored “a great deal of focus by the I.R.S. on international business, international people and the global economy.”

In previous years, he said, the agency’s domestic examiners and auditors had the last word on whether to pursue or settle specific cases against large multinational corporations,

a power structure that frustrated the I.R.S.’s international examiners.

“The domestic agent would say, ‘I’m ready to settle,’ and the international agent would say no” — and lose, Mr. Langdon said.

The reorganized unit will also have a director focused for the first time on transfer pricing, a growing area of I.R.S. scrutiny.

Transfer pricing is a technique employed routinely, and sometimes abusively, by multinational corporations to reduce their taxes by keeping profits offshore in low- or no-tax havens.

Douglas H. Shulman, the I.R.S. commissioner, said in an interview that

the shift would “build up our expertise and sharpen our focus” on the international component of thorny tax problems and tax evasion.

“International is going to stay a top priority at the agency,” he said.

Various government and policy research studies show that large corporations are increasingly using gray areas of the tax code to minimize or illegally evade billions of dollars in taxes a year through complex international structures.

About 875 examiners and economists who were focused on international issues in the existing unit

will join 600 others who were also working on the issues to form a single international team within the reorganized unit,

which has been known as the large and midsize business division.

The overall number of agency employees will remain the same.

The new unit will be in charge of examining whether financial institutions are complying with a new law, the Foreign Account Tax Compliance Act,

which requires them to disclose, by 2013, the details of American clients with undeclared offshore accounts or withhold a 35 percent tax on those accounts.

The unit will also scrutinize partnerships and wealthy individuals with at least $10 million in assets.

In another shift, the international examiners will no longer work according to industries and geographic areas, but instead will be assigned to specific high-priority cases.

The changes come after a shift last fall in which the I.R.S. created within the core unit a division focused on wealthy individuals

during a crackdown on tax evasion by affluent clients at the Swiss bank UBS, according to this article in the New York Times.