2025 IRS Enforcement Update: Key Areas of Focus for Examinations, Audits, and Criminal Cases

Tax enforcement is expected to have a substantial increase throughout 2025. Tax professionals must grasp a complete understanding of recent IRS enforcement initiatives and plan accordingly for impacted taxpayers.

Recent IRS enforcement actions and tax disputes have involved (1) increases in the examination of high-income taxpayers; (2) the use of the economic substance doctrine in transfer pricing examinations; (3) crypto-focused audits and criminal cases; and (4) a crackdown on abusive transactions.

In addition, more examinations and tax disputes are expected due to proposed restrictions on access to IRS appeals for certain matters. Taxpayers and tax advisers must be prepared to handle increased IRS scrutiny and plan accordingly for transactions and reporting to better defend against the impending wave of tax enforcement.

Listen as our panel discusses recent IRS investigations and tax cases, abusive tax avoidance transactions, crypto-related audits, digital asset cases, transfer pricing, and examinations of high-income taxpayers. The panel will also offer tactics for navigating the processes involved for examinations, penalties, and criminal cases.

1. High-income taxpayers
2. Transfer pricing examinations
3. Crypto and other digital asset transactions
4. Abusive tax avoidance transactions
5. Other IRS areas of focus and key considerations for taxpayers

The panel will discuss these and other key issues:

• What have been the key areas of focus in recent IRS investigations and tax disputes?
• What tax reporting and compliance issues arise for high-income taxpayers?
• What is the IRS' current outlook and treatment of crypto transactions and reporting?
• What transactions have the IRS considered to be abusive tax avoidance transactions?
• How to navigate IRS investigations and avoid or limit penalties or criminal liability