How IRS Attorney Departures Will Prolong Cases, Spur Settlements

Big job cuts and reductions in resources at the IRS are liable to prolong disputes over tax bills and force the agency to leave money on the table when cases are finally resolved. More than 170 attorneys have withdrawn from representing the IRS in cases in US Tax Court since Donald Trump became president in January, according to a Bloomberg Tax analysis. Many have quit the IRS altogether amid a major exodus of employees. Some Justice Department attorneys who represented the IRS in tax disputes in federal appeals courts have also left, moves that could impact some of the biggest, most prominent tax-related cases in the courts. The diminished resources suggest it’ll take longer to resolve cases, former attorneys and former IRS and DOJ officials say. The IRS may also be pushed into considering settlements in some cases where perhaps it wouldn’t otherwise. That would mean settling cases on less favorable terms for the agency, and potentially give taxpayers a leg up in dealing with the IRS. In this episode of Talking Tax, Bloomberg Tax senior reporter Michael Rapoport discusses the attorney departures and their implications, as well as attorneys’ frustrations about their jobs and fears about the future that prompted some to leave the IRS. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

President Donald Trump's widespread tariffs are boosting tax dispute risks for companies that are scrambling to understand how to factor the new trade duties into their transfer pricing and tax planning without attracting an audit. Tariffs raise the prices of imported goods, meaning companies importing products from their own affiliates may have to—or want to—adjust the pricing of those transactions to meet transfer pricing rules that require them to treat the deals as though they were done at arm's length, with unrelated parties. The added cost of the tariff will likely knock the pricing for many goods out of that arm's-length range, so companies may have to adjust these prices to stay compliant. Additionally, companies may be able to make adjustments to mitigate the tariff impacts by reducing the price the US entity pays for the good. These adjustments can attract scrutiny, however, from both tax and customs agencies. And growing geopolitical tensions may make it hard for companies to rely on tax dispute resolution mechanisms like mutual agreement procedures. In this episode of the Talking Tax Podcast, Crowe LLP transfer pricing practice leader Sowmya Varadharajan talked with reporter Caleb Harshberger about the choices, and risks, companies are facing. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax preparers consider themselves foot soldiers on the front lines of Americans' income tax preparations. They provide advice and file the returns, helping the government collect its revenue and make sure people are paying their fair share. They are also some of the first to warn taxpayers about scams. This group of preparers includes enrolled agents, who are the only federally licensed tax practitioners.  Enrolled agents now are assessing what the recent exodus of thousands of IRS workers and agency leadership means for filing season. They're also watching for guidance for how to implement new policies from the massive 2025 GOP tax law. Bloomberg Tax’s Erin Slowey spoke with Jennifer MacMillan, president of the National Association of Enrolled Agents, about rules related to overtime and tips from that new tax law, the regulation of tax preparers, and what happens next at the IRS as its workforce has been slashed. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Congress is back in session with just a few weeks to reach an agreement before government funding runs out Sept. 30. For IRS watchers, the lack of agreement on how to fund the tax collection agency or whether to extend expiring tax breaks rank among the key issues lawmakers will grapple with over the coming months. In this week’s episode of Talking Tax, Bloomberg Tax reporter Zach C. Cohen and Bloomberg Government reporter Maeve Sheehey preview the government funding fight and potential movement on budget reconciliation bills, and the impact on tax policy and administration. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

As President Donald Trump's tariffs make waves in the world economy, multinational companies are mulling what it could mean for their intangible assets like intellectual property and brand recognition. The vast majority of corporate value comes from intangibles. In 2020, such assets made up 90% of the value of the S&P 500, according to an often-cited study by IP consultant Ocean Tomo—up from up from just 17% in 1975. Tariffs don’t directly levy fees on intangibles, but their value is often embedded into imported products, raising the tariffed price. These intangible assets can also come with a smorgasbord of options for companies to locate IP in countries to best blunt the impacts of tariffs or reduce taxes on their business. On this episode of Talking Tax, Grant Thornton principal Glen Marku talked with reporter Caleb Harshberger about what companies' intangible assets could mean for their tariffs exposure and whether they need to rethink their tax planning. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Big Four accounting firms are racing to integrate next-generation AI technology across their service lines and develop a talent strategy to match the industry's new era. KPMG is focused on making sure it's balancing efficiency gains because of artificial intelligence with long-term workforce development, according to Sandy Torchia, vice chair of talent and culture at KPMG US. The firm has created new learning opportunities for workers to teach them how to use AI to enhance career growth, she said. Like its competitors, KPMG has rolled out new autonomous AI that can accomplish tasks with minimal human intervention. The industry's next generation is taking note. The vast majority of KPMG's US interns expect at least 20% of their work to be automated by AI by the time they start full-time positions, according to the firm's recent survey. Torchia, who is also head of people for KPMG's Americas region, recently stepped into a new role as global co-head of people for KPMG International. She spoke with Bloomberg Tax reporter Jorja Siemons about how KPMG is helping employees adapt to an AI-led future, as well as the state of hybrid work and the CPA pipeline. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Proof from an ancient Roman scroll: As long as there have been taxes, there has been tax evasion. When researchers studied a previously mislabeled scroll, they discovered detailed attorney notes for a case against taxpayers accused of using forged documents and sham transactions between the Roman provinces of Judaea and Arabia to escape taxes on their assets. The assets in question were enslaved people. The potential punishments included distinctly unmodern measures. Anna Dolganov of the Austrian Academy of Sciencescq talked with reporter Caleb Harshberger about how scholars made the discovery, details of the scheme, and what they're hoping to uncover next as they continue their research. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Pharmaceutical companies are scrambling to respond to the Trump administration's tariff threats, seeking to mitigate duties on their products while keeping the impact on their tax bills to a minimum.   The industry has long leveraged complex transfer pricing arrangements to cut down on its tax bills, but now the looming tariffs could spark a major rethink for where companies make their drugs and the location of their crown jewel: the intellectual property. Pharmaceuticals were exempt from the initial wave of tariffs announced earlier this year, but subsequent months have seen threats of heavy fines and taxes from the administration and a looming national security investigation, which could result in heavy duties on the industry.   In this week's Talking Tax podcast, Cronus Consulting founder Nick Shipley talked with reporter Caleb Harshberger about how pharmaceutical companies are navigating the chaos, and what it could mean for their tax planning and operations. Shipley is a consultant for the pharmaceutical industry. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

One of the most unwanted jobs in Washington is now up for grabs—again. President Donald Trump's IRS commissioner, Billy Long, exited as the head role last week and is expected to be nominated as the ambassador to Iceland. Treasury Secretary Scott Bessent will fill the job in the interim. The vacancy at the top of the IRS continues the turbulence the agency has experienced since the start of the Trump administration. Now, the question of who will be nominated next—if at all—remains. In this episode of Talking Tax, Bloomberg Tax reporter Erin Slowey discusses how the IRS got to this point and what it means for the future of the agency. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

It’s been four months since the Trump administration announced its “Liberation Day” tariffs, and companies are still scrambling to make sense of what it means for their operations and tax planning. Rates keep changing, sometimes day to day, as countries struggle to make lasting trade deals with the US, while corporate tax and customs departments put their heads together to minimize the costs to their companies—without attracting a big audit. In this special Talking Tax podcast—the first of four on transfer pricing and tariffs—PwC principal Chris Desmond talks with Bloomberg Tax reporter Caleb Harshberger about the ways companies have been trying to adjust to the new reality. These include emergency meetings with top executives and heads of tax, trade, and other functions across the company, and deep dives into customs rules that many company executives hadn't felt the need to know well—until now. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.