The Inflation Reduction Act of 2022 (IRA), passed into law on August 16, 2022, represented a shift in the world of U.S. federal tax enforcement. This shift—or as most might suggest, a reversal of course—departed from the IRS that many have come to know in recent years, maligned by funding cuts, widespread attrition, and loss of institutional knowledge needed to administer the nation’s complex set of federal tax laws.

On September 8, 2023, the IRS announced that it will start a “sweeping, historic effort to restore fairness in tax compliance” by focusing its attention on high-income taxpayers, partnerships, large corporations, and promoters.

The Supreme Court has released its 5–4 decision in Bittner v. United States, No. 21-1195, holding that the Bank Secrecy Act’s penalty for non-willful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) applies on a per-form basis—and not on a per-account basis, as argued by the government.