differing definitions are only part of the problem.
by 卡塔尔世界杯常规比赛时间 research
the inflation reduction act endowed the irs with almost $80 billion to improve customer service and beef up enforcement. congress later reduced the amount to $57.8 billion, with $24 billion earmarked for enforcement.
in no time at all, there was misinformation bouncing around social media and conservative podcasts, claiming that the ira would result in more audits of middle-class taxpayers.
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the enforcement resources had no such designation. to allay fears, in 2022 the secretary of the treasury directed the irs commissioner not to use any of the additional resources to increase the audit rate of small businesses or households earning below $400,000.
the secretary’s precise words:
“… enforcement resources will focus on high-end noncompliance. there, sustained, multiyear funding is so critical to the agency’s ability to make the investments needed to pursue a robust attack on the tax gap by targeting crucial challenges, like large corporations, high-net-worth individuals and complex passthroughs, where today the irs has resources to initiate just 7,500 audits annually out of more than 4 million returns received.”
it’s complicated
that part of the directive seems clear enough, but of course, this being the irs, it gets complicated.
the complication is over the use of “increase.” the irs is supposed to increase audits of households earning over $400,000, not those earning under that amount. but increase over what baseline?
the baseline year is 2018. the complication is in the methodology of calculating the audit rate in that year and subsequently years starting with fy 2024.
the irs initially proposed excluding certain types of examinations when computing the audit coverage rate. the irs wanted the authority to waive certain examinations if taxpayers seemed to have intentionally understated income to avoid the $400,000 threshold. but the treasury inspector general for tax administration expressed concern that the waiver criteria were too vague and therefore would erode trust in the irs.
there was also concern over whether an absolute threshold put married couples filing jointly at a disadvantage when their joint income surpassed the threshold. the irs has no plans for special treatment in such cases, pointing out that the 2022 treasury directive made no distinction between joint filings and single households.
methodology options
but waivers aren’t the reason the 2018 audit coverage rate hasn’t been calculated. the reason is that the irs and treasury are exploring a range of methodology options for compliance with the 2022 directive.
one thing they need to figure out is whether certain classifications of of examinations should be included or removed from the calculations.
generally, the audit coverage rate is defined as the degree to which a certain type of tax return is audited compared with the total number of that type of return. the formula is deceptively simple: the total number of returns audited (the numerator) divided by the total number of returns (the denominator).
but wait a minute. shouldn’t there be some kind of allowance for audits that shouldn’t be in the calculation? for example, should examinations of amended returns be excluded because they are not “discretionary”? and what about including suspicious returns that squeak under the $400,000 line?
it got to be too complicated, so the irs ditched the possibility of any kind of waivers.
how small is small?
and then there was a question of what defines a “small business.” neither the 2022 directive nor the u.s. tax code define the term. but the irs currently defines it as a business with less than $10 million assets.
meanwhile, the small business administration defines small business by revenue, ranging from $1 million to $40 million, and employment, from 100 to 1,500 employees. that definition varies by industry.
and then there’s the question of the applying the definition to s corporations and partnerships.
as yet, there is no timeline to develop definitions and calculations. and apparently there’s no need to hurry. the irs does not intend to calculate audit coverage rates until 2025.
the treasury inspector general for tax administration’s recommendation: “the deputy commissioner [of the irs] should accelerate discussions with the treasury department to finalize the audit rate methodology for the 2022 treasury directive.”
or, in other words: git ’er done.