IRS Enforcement Tools

Audits, schedule UTP, CAP, and the economic substance doctrine are among the IRS’s most effective enforcement tools. This session will explore:

• Recent case law interpreting Code Section 7701(o)
• IRS use of information gathered from the Schedule UTP (in which asset thresholds declined precipitously for the 2012 tax year)
• IRS attention and direction given to each of these compliance tools
• How each of these compliance tools may be impacted by the outcome of the November election