2025 IRS Enforcement Update: Key Areas of Focus for Examinations, Audits, and Criminal Cases
Abusive Tax Avoidance Transactions, Crypto-Related Audits, Digital Asset Cases, Transfer Pricing, High-Income Taxpayers

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Monday, April 28, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE/CPE webinar will provide guidance to tax professionals on the 2025 IRS enforcement initiatives and key issues for taxpayers. The panel will discuss recent IRS investigations, abusive tax avoidance transactions, increased 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.
Faculty

Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense, federal tax controversies, financial institution regulatory compliance, and complex civil litigation. He has significant experience in conducting corporate internal investigations and advising banks and financial institutions as to compliance issues involving FATCA, the Bank Secrecy Act, the USA Patriot Act, anti-money laundering laws and regulations, and economic sanctions. He also represents financial institutions in enforcement proceedings brought by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN).

Mr. Nemeth is a partner and leads the firm’s Tax Planning, Compliance and Litigation Practice Team. He has extensive experience in tax law with a focus on all aspects of related civil and criminal law, as well as complex financial investigative and litigation matters.
Description
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.
Outline
- High-income taxpayers
- Transfer pricing examinations
- Crypto and other digital asset transactions
- Abusive tax avoidance transactions
- Other IRS areas of focus and key considerations for taxpayers
Benefits
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
Unlimited access to premium CLE courses:
- Annual access
- Available live and on-demand
- Best for attorneys and legal professionals
Unlimited access to premium CPE courses.:
- Annual access
- Available live and on-demand
- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
- Available live and on-demand
- Best for legal, accounting, and tax professionals
Unlimited access to Professional Skills and Practice-Ready courses:
- Annual access
- Available on-demand
- Best for new attorneys
Related Courses

Tax Counsel's Guide to Partnership Disguised Sales Rules: Structuring Transactions to Avoid Taxable Events
Friday, July 18, 2025
1:00 p.m. ET./10:00 a.m. PT

2025 Tax Reform for Non-U.S. Investors and Companies: International Tax Provisions in the One Big Beautiful Bill Act
Monday, June 16, 2025
1:00 p.m. ET./10:00 a.m. PT
Recommended Resources
How CPE Can Bridge the Gap Between What You Know and What You Need to Know
- Career Advancement
Gain a Competitive Edge Through Efficient CPE Strategies
- Learning & Development
- Business & Professional Skills
- Career Advancement