GOP Unveils Plan To Make 2017 Tax Cuts Permanent & Expand Estate Tax Exemption

According to Law360, House Republicans plan to meet Tuesday to deliberate a sweeping extension of their 2017 tax overhaul that would lock in low individual rates and deduction limits, expand child care and estate tax breaks, and make permanent tax incentives for small pass-through businesses and U.S. multinational corporations.

The 28-page tax bill, released late Friday by House Ways and Means Committee Chairman Jason Smith, R-Mo., would expand most of the popular tax incentives in the 2017 Tax Cuts and Jobs Act, the signature legislation of President Donald Trump's first term. The tax bill is the product of intense negotiations between House and Senate GOP lawmakers and the White House, who hope for a vote on it by Memorial Day.

Smith's bill would make TCJA individual tax rates permanent by removing the sunset date of Dec. 31, 2025, and would permanently extend the doubled standard deduction with a temporary increase through 2028 of $1,500 for married taxpayers and $1,000 for individuals.

Personal exemptions and miscellaneous itemized deductions would be repealed permanently, and the child tax credit would be increased to $2,500 per child through 2028 before dropping to a permanent credit of $2,000. The bill would require both parents to have Social Security numbers in order to claim the credit.

The exemption for estate and gift taxes would be permanently raised to $15 million per spouse, from $13.99 million per spouse, and indexed for inflation. The TCJA exemption from the alternative minimum tax would also be made permanent.

On the business side, the bill would: 

• permanently extend the deductions for foreign-derived intangible income and global intangible low-tax income. 
• It would also repeal a scheduled increase in the base erosion and anti-abuse tax. and 
• The bill would also extend the deduction for qualified pass-through business income and increase the deduction rate to 22%.

In A Statement Released Along With The Legislation,
Smith Said The Bill Would Usher In A New Age Of Prosperity
By Building On The TCJA's Successes.

According to a Joint Committee on Taxation report released Saturday, the bill would cost $4.9 trillion over the next decade, including nearly $2.2 trillion to make the Tax Cuts and Jobs Act's individual tax rates permanent. The increased standard deduction would cost nearly $1.3 trillion, but permanently eliminating personal exemptions would raise nearly $1.9 trillion in revenue over the next 10 years, according to the report.

• The bill would lower the average tax rate for those making more than $1 million in annual income from 30.7% to 27.4%, according to a second report released by the JCT on Saturday. 
• The average tax rate for taxpayers making $500,000 to $1 million would be reduced from 29.9% to 25.8%.

The legislation is subject to change and will likely be significantly altered if it eventually is passed into law. For example, it is silent on the fate of the $10,000 cap on state and local tax deductions, one of the most debated provisions of the TCJA, nor does it include Trump's campaign promise of ending the taxation of tipped income or the tax break for carried interest.

The House Ways and Means Committee's ranking member, Rep. Richard Neal, D-Mass., faulted Republicans for releasing the bill late Friday and, he said, omitting major parts of the legislation.

"I'll Tell You What's Coming: Handouts For Billionaires, Healthcare Cuts For The People," He Said In A Statement.

Trump said Friday that he and other Republicans would graciously accept a "tiny" tax increase for the rich to help lower- and middle-income workers. "Republicans should probably not do it, but I'm OK if they do!!!" Trump said in a post on Truth Social.

To fully extend and build upon the 2017 tax cuts, this means that the reconciliation bill must include at least $2 trillion in verifiable savings either through spending reductions or scaling back the size of the tax package," the group said. "If savings fall short, the Ways and Means Committee's instruction must be lowered dollar-for-dollar to keep the reconciliation bill within the agreed limits."

Have IRS Tax Problems?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243) 

Credit Suisse Admits to Conspiring to Hide $4 Billion of US Taxpayer's Assets in Breach of Its 2014 Plea Agreement

According to DoJ, Credit Suisse Services AG pleaded guilty and was sentenced on May 5, 2025 to conspiring to hide more than $4 billion from the IRS in at least 475 offshore accounts. The guilty plea by the Swiss corporation is the result of a years-long investigation by U.S. law enforcement to uncover financial fraud and abuse.

In addition to the plea, Credit Suisse Services AG entered into a non-prosecution agreement (NPA) with the Justice Department’s Tax Division and U.S. Attorney’s Office for the Eastern District of Virginia in connection with U.S. Accounts booked at Credit Suisse AG Singapore. Under the NPA, Credit Suisse Services AG agreed to cooperate with the Justice Department in ongoing investigations and to pay significant monetary penalties for maintaining accounts in Singapore on behalf of U.S. taxpayers who were using offshore accounts to evade U.S. taxes and reporting requirements.

According to the Plea Agreement, NPA, and documents filed in court today: from Jan. 1, 2010, and continuing until about July 2021, Credit Suisse AG, which had ultra-high-net-worth and high-net-worth individual clients around the globe, conspired with employees, U.S. customers, and others to willfully aid U.S. customers in concealing their ownership and control of assets and funds held at the bank. 

This enabled those U.S. customers to evade their U.S. tax obligations in several ways, including by opening and maintaining undeclared offshore accounts for U.S. taxpayers at Credit Suisse AG, and providing a variety of offshore private banking services that assisted U.S. taxpayers in the concealment of their assets and income from the IRS and allowed for their continued failure to file FBARs. 

Among Other Fraudulent Acts, Bankers At Credit Suisse Falsified Records, Processed Fictitious Donation Paperwork,
And Serviced More Than $1 Billion In Accounts Without Documentation Of Tax Compliance.

In doing so, Credit Suisse AG committed new crimes and breached its May 2014 plea agreement with the United States.

Between 2014 and June 2023, Credit Suisse AG Singapore held undeclared accounts for U.S. persons, which Credit Suisse AG Singapore knew or should have known were U.S., with total assets valued at over $2 billion. Credit Suisse AG Singapore failed to adequately identify the true beneficial owners of accounts and failed to conduct adequate inquiry about U.S. indicia in the accounts. In 2023, during the post-merger of UBS AG Singapore and Credit Suisse AG Singapore, UBS became aware of accounts held at Credit Suisse AG Singapore that appeared to be undeclared U.S. accounts. UBS froze some of the accounts, voluntarily disclosed information about those identified accounts to the Justice Department and cooperated by undertaking an investigation into the identified accounts.

Under today’s resolutions, Credit Suisse Services AG and, by extension, UBS AG, is required to cooperate fully with ongoing investigations and affirmatively disclose any information it may later uncover regarding U.S.-related accounts. The agreements provide no protections for any individuals. Pursuant to the guilty plea and the NPA, Credit Suisse Services AG will pay a total of $510,608,909 in penalties, restitution, forfeiture, and fines.

Do You Have Undeclared Income from
an Offshore Bank or Financial Advisors?

Is Your Name Being Handed Over to the IRS?

Want to Know if Voluntary Disclosure is Right for You?

Contact the Tax Lawyers at 

Marini & Associates, P.A.   

for a FREE Tax Consultation contact us at:

www.TaxAid.com or www.OVDPLaw.com 

or Toll Free at 888-8TaxAid (888) 882-9243  

TIGTA Issues IRS Workforce Reduction Report as of March 2025

According to TIGTA IRS Workforce Reduction Report, Since January 2025, there have been several executive orders to reduce the size of the federal workforce. 

In February 2025, the IRS had approximately 103,000 employees. Since then, more than 11,400 IRS employees either received termination notices as probationary employees or voluntarily resigned, representing an 11% reduction to the agency's workforce. 

This is separate from and in addition to IRS Appeals Staffing Cuts and Hundreds of Deferred Resignations.

Specifically:

• 7,315 probationary employees received termination notices.
• 4,128 employees were approved to accept the Deferred Resignation Program (an additional 522 employees are pending approval).

This is our first report on IRS workforce reductions and it focuses on the probationary employees identified for termination and the employees who voluntarily participated in the initial Deferred Resignation Program. 

We'll periodically update this report to highlight further reductions, including the impacts of the second Deferred Resignation Program and Reductions in Force.

• More than 3,600 IRS agents responsible for audits have been either approved for deferred resignation or terminated, marking a 31% reduction to the agency's revenue agent workforce.
• More than 11,000 IRS employees overall have been approved for voluntary resignation with pay through Sept. 30 or received termination notices during their probationary employment period as of March.
• 7,315 probationary employees received termination notices.
• 4,128 employees were approved to accept voluntary resignations
• Nearly 6,700 terminated probationary employees had been at the agency for one year or less, while 31 employees had been at the agency for more than five years, according to the report.
• Nearly 2,600 of the agency's contact representatives have been laid off or voluntarily resigned. 
• just over 1,600 of tax examiners have been laid off or voluntarily resigned, according to the report. 
• A little over 600 revenue officers have separated from the agency.
• The agency's Small Business/Self Employed business unit's workforce has lost  5,765 employees leaving the agency. 
• Taxpayer services lost just over 1,700 employees. 

Since March, the IRS has indicated further staffing cuts, including 75% of the agency's Office of Civil Rights and Compliance and at the Taxpayer Experience Office and the Office of Equity, Diversity and Inclusion in Taxpayer Services, according to the report.

Have an IRS Tax Problem?

 Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

 

TIGTA Reports That The IRS Successfully Targeting Rich Non-filers

On November 3, 2020 we posted The IRS Wealth Squad - The Super-Richest's Worst Nightmare, where we discussed that high-net-worth individuals may find themselves the focus of unwanted attention from the Internal Revenue Service. 

Now TIGTA reveals the results of these Internal Revenue Service targeted sweeps of so-called high-income non-filers, which have largely been successful in closing cases and collecting revenue, but the agency could do more to target certain areas and collect tracking data better, the Treasury Inspector General for Tax Administration said.

The Sweeps From 2021 And 2022 Resulted In More Case Closures And Dollars Collected Than High-Income Nonfiler Cases Not Handled Through Sweeps, TIGTA Said In A Report.

HINF sweeps cases worked by revenue officers from Fiscal Years 2021 through 2022 were more impactful in terms of case closures and dollars collected than non-sweeps HINF cases. As a percentage of cases worked, revenue officers secured more returns under sweeps than non-sweeps and referred significantly more returns to Examination. For Tax Years 2014 through 2020, revenue officers consistently collected more per sweep case than non-sweep case. 

Sweeps were conducted throughout the United States and internationally. However, there are several geographic areas in the continental United States that have a high number of HINFs where limited or no sweeps were conducted. There are opportunities for more sweeps in places like eastern New Mexico, western Texas, northwestern Nevada, and Wyoming. 

TIGTA'S review also found that the sweeps tracking data could be improved. Missing, incomplete, and/or inaccurate data were found in data fields such as the taxpayer’s name, address, revenue officer identifier, and case assignment date. These errors were not identified and corrected before this review. We worked with the IRS to make corrections so that the data reviewed for this audit were accurate and complete. However, the IRS would benefit from complete and accurate data to track the results of sweeps. 

Finally, Field Collection is not always using sweeps to help train and develop employee skills. While the sweeps desk guide provides the IRS with many opportunities to develop employee skills, Collection management is not always taking advantage of them. These activities have the potential to make sweeps an even more effective tool.

Are You Being Audited by the IRS Wealth Squad?

Contact the Tax Lawyers at 

Marini & Associates, P.A.

 

for a FREE Tax Consultation

at www.TaxAid.us or www.TaxLaw.ms

or Toll Free at 888-8TaxAid (888 882-9243)

 

When Unpaid Taxes Can Cost You Your Passport: The Pfirrman Case

Did you know that owing the IRS can put your passport at risk? That’s exactly what happened to Drew Pfirrman, a Florida resident who recently lost his Tax Court case after the IRS certified his “seriously delinquent tax debt.”

What Happened?

·         Unreported Income: The IRS found Pfirrman had over $367,000 in unreported income for 2018 and hit him with a six-figure tax bill, penalties, and interest.

·         IRS Notices Ignored: He missed his chance to challenge the debt through the proper IRS channels.

·         Passport in Jeopardy: When his tax debt grew to over $182,000, the IRS notified the State Department, threatening his passport.

Can You Fight It?

Pfirrman tried to argue that his debt was lower and that partial payments should help. But the Tax Court ruled it can’t reconsider the original tax bill in a passport case. Only full payment of the debt (or qualifying for a special exception) can get your passport privileges restored.

The Lesson

Don’t ignore IRS notices. If you owe big, act fast-set up a payment plan or pay in full. Once the IRS certifies your debt, it’s too late to argue about the amount in court, and your travel plans could be grounded. 

See also our post TC Determines That Taxpayer's Debt Was 'Seriously Delinquent' Even after He Paid Tax to Reduce Balance below $50,000 where we discussed that once a certification of a seriously delinquent tax debt has been made, it may be reversed "if the debt with respect to such certification is fully satisfied." I.R.C§ 7345(c)(1) (emphasis added).

If You Have Serious Delinquent IRS Debt, You Should Consult with Experienced Tax Attorneys, As There Are Several Ways Taxpayers Can Avoid Having the IRS Request That the State Department Revoke Your Passport. 

  Want To Keep Your US Passport?
 

 

Contact the Tax Lawyers at 

Marini & Associates, P.A.

for a FREE Tax Consultation Contact us at:

www.TaxAid.com or www.OVDPLaw.com 

or Toll Free at 888-8TaxAid (888)882-9243.

References

1.       https://www.currentfederaltaxdevelopments.com/blog/2025/3/18/irs-properly-certified-seriously-delinquent-tax-debt-to-state-department-leading-to-potential-loss-of-passport             

2.      https://www.thetaxadviser.com/issues/2025/mar/certification-of-seriously-delinquent-tax-debt-not-erroneous/           

3.      https://www.leagle.com/decision/intco20250318g64  

4.      https://www.irs.gov/pub/irs-access/p5827_accessible.pdf   

5.       https://www.irs.gov/businesses/small-businesses-self-employed/revocation-or-denial-of-passport-in-cases-of-certain-unpaid-taxes 

IRS Appeals Staffing Cuts and Hundreds of Deferred Resignations

The IRS Independent Office of Appeals, led by Chief Liz Askey since last year, is currently navigating significant workforce challenges. At the start of the calendar year, Appeals had about 1,777 employees. However, the office is experiencing notable attrition:

·         Approximately 77 probationary employees are on administrative leave and unable to work.

·         Over 300 employees have signed deferred resignation agreements, with another 100 pending.

·         A substantial portion (43%) of staff are retirement-eligible or early retirement-eligible, contributing to the high number of departures.

As a result, Askey projects that by the end of the current fiscal year, the Appeals workforce will be reduced to around 1,324 employees. Compounding these losses, the office is under a hiring freeze for both internal and external candidates. Askey anticipates that after current workforce reduction and reshaping efforts conclude, Appeals may be able to hire from the IRS compliance function to address short-staffing.

Summary Table: IRS Independent Office of Appeals-Current State

Aspect	Current Status/Trend
Staffing	Down from 1,777 to projected 1,324; hiring freeze in effect
Cycle Times	Non-docketed cases at 274 days (FY25), lowest in 6 years
Conference Options	In-person, phone, video, correspondence; taxpayer preference honored
Accessibility Efforts	Circuit riding, hybrid options, public input sought
Technology Initiatives	Paperless pilot for smaller files

Case Cycle Times: Progress Despite Constraints

Despite these staffing reductions and hiring limitations, Appeals has made measurable progress in reducing case cycle times:

·         The average cycle time for non-docketed cases in fiscal year 2025 is now 274 days, the lowest level in six years.

·         This is a significant improvement from the 2022 National Taxpayer Advocate report, which cited a 365-day average for non-docketed cases-a 103% increase over 2017 cycle times.

·         Askey attributes this improvement to targeted efforts, including analyzing and reducing delays in getting cases to Appeals and implementing a "paperless pilot" for scanning smaller case files upon receipt, streamlining case handling.

Askey remains "cautiously optimistic" that these trends will continue, even as workforce changes persist.

Conference Options: In-Person, Virtual, and Hybrid

Appeals offers taxpayers several ways to resolve disputes, including:

·         In-person conferences

·         Telephone conferences

·         Video conferences (using Microsoft Teams)

·         Correspondence or secure messaging

The office has a longstanding policy of accommodating taxpayer preferences for conference format, especially for larger and more complex cases. While there was a temporary shift to virtual conferences due to recent travel policy changes, a new travel approval process is now in place. Appeals Officers can again travel for in-person conferences, though more lead time is required for approval.

For taxpayers not near an Appeals office, the office continues to use "circuit riding," where Appeals Officers travel to more convenient locations, and is seeking public input on improving accessibility and hybrid conference options.

Have an IRS Tax Problem?

 Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

 

Sources:

1.       https://www.irs.gov/appeals/what-to-expect-from-the-independent-office-of-appeals  

2.      https://www.irs.gov/newsroom/improving-nationwide-access-to-irs-appeals-public-input-wanted    

3.      https://www.irs.gov/appeals/appeals-expands-access-to-video-conferences 

4.    https://irstaxtrouble.com/irs-appeals-guidance-on-in-person-conferences/