December 6, 2021

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North Carolina Return Preparer Pleads Guilty to Tax Fraud Scheme

9 min read
<div>A North Carolina return preparer pleaded guilty today to conspiring to defraud the United States.</div>
A North Carolina return preparer pleaded guilty today to conspiring to defraud the United States.

More from: March 3, 2021

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  • Justice Department and Office of the Comptroller of the Currency Announce Actions to Resolve Lending Discrimination Claims Against Cadence Bank
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    The Justice Department and the Office of the Comptroller of the Currency (OCC) today announced coordinated actions to address allegations of lending discrimination by Cadence Bank N.A.
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  • Afghanistan: Improvements Needed to Strengthen Management of U.S. Civilian Presence
    In U.S GAO News
    What GAO FoundU.S. agencies under Chief of Mission authority and the Department of Defense (DOD) have reported expanding their civilian presence in Afghanistan and took steps to improve their ability to track that presence. Since January 2009, U.S. agencies under Chief of Mission authority more than tripled their civilian presence from 320 to 1,142. However, although State could report total Chief of Mission numbers by agency, in mid-2011 GAO identified discrepancies in State’s data system used to capture more-detailed staffing information such as location and position type. State began taking steps in the fall of 2011 to improve the reliability of its data system. Also, DOD reported expanding its overall civilian presence from 394 civilians in January 2009 to 2,929 in December 2011 to help assist U.S. efforts in Afghanistan. The extent to which DOD’s data is reliable is unknown due to omissions and double counting, among other things. In a 2009 report, GAO noted similar data issues and recommended DOD improve data concerning deployed civilians. DOD concurred with the recommendation and expects the issues will be addressed by a new tracking system to be completed in fiscal year 2012.DOD has taken preliminary steps to implement its Civilian Expeditionary Workforce (CEW) policy, including establishing a program office; however, nearly 3 years after DOD’s directive established the CEW, the program has not been fully developed and implemented. Specifically, DOD components have not identified and designated the number and types of positions that should constitute the CEW because guidance for making such determinations has not been provided by the Office of the Secretary of Defense. Officials stated that once key assumptions regarding the size and composition of the CEW have been finalized, implementing guidance will be issued. Until guidance that instructs the components on how to identify and designate the number and types of positions that will constitute the CEW is developed, DOD may not be able to (1) make the CEW a significant portion of the civilian workforce as called for in DOD’s fiscal year 2009 Civilian Human Capital Strategic Plan, (2) meet readiness goals for the CEW as required in DOD’s Strategic Management Plan for fiscal years 2012-2013, and (3) position itself to respond to future missions.U.S. agencies under Chief of Mission authority and DOD provided Afghanistan-specific, predeployment training to their civilians, but DOD faced challenges. State offered predeployment training courses to address its requirements for Chief of Mission personnel and designated a centralized point of contact to help ensure that no personnel were deployed without taking required training, including the Foreign Affairs Counter Threat course. While predeployment training requirements were established for Afghanistan by the Office of the Secretary of Defense and the Combatant Commander, DOD relied on its various components to provide the training to its civilians. In some cases, DOD components offered duplicate training courses and did not address all theater requirements in their training because DOD did not have a process for identifying and synchronizing requirements and coordinating efforts to implement them, as called for in the Strategic Plan for the Next Generation of Training for the Department of Defense. Absent this process, DOD could not ensure that its civilians were fully prepared for deployment to Afghanistan and that training resources were used efficiently.Why GAO Did This StudyIn March 2009, the President called for an expanded U.S. civilian presence under Chief of Mission authority to build the capacity of the Afghan government to provide security, essential services, and economic development. In addition, the Department of Defense (DOD) deploys civilians under combatant commander authority to Afghanistan to support both combat and capacity-building missions. DOD established the Civilian Expeditionary Workforce (CEW) in 2009 to create a cadre of civilians trained, cleared, and equipped to respond urgently to expeditionary requirements. As the military draws down, U.S. civilians will remain crucial to achieving the goal of transferring lead security responsibility to the Afghan government in 2014.For this report, GAO (1) examined the expansion of the U.S. civilian presence in Afghanistan, (2) evaluated DOD’s implementation of its CEW policy, and (3) determined the extent to which U.S. agencies had provided required Afghanistan-specific training to their personnel before deployment. GAO analyzed staffing data and training requirements, and interviewed cognizant officials from the Department of State (State), other U.S. agencies with personnel under Chief of Mission authority in Afghanistan, and DOD.
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  • Defense Contractors: Information on Violations of Safety, Health, and Fair Labor Standards
    In U.S GAO News
    GAO's analysis of federal data found that about 1 percent of companies with Department of Defense (DOD) contracts were cited for willful or repeated safety, health, or fair labor violations in fiscal years 2015 through 2019. However, these data do not indicate whether the violations occurred while performing work related to a defense contract. Companies with DOD Contracts Cited for Willful or Repeated Violations under the Fair Labor Standards Act of 1938 or the Occupational Safety and Health Act of 1970, Fiscal Years 2015 through 2019 Because of limitations in available data, GAO could not determine the total incidence of willful or repeated violations of safety, health, or fair labor standards among all companies with a defense contract in this 5-year time frame. Specifically, about 43 percent of the Department of Labor's (Labor) safety and health violation data did not include key company identification numbers. These numbers are necessary to match federal contracting data to violation data. GAO recommended in February 2019 that Labor explore ways to address this issue. While Labor neither agreed nor disagreed with the recommendation, it issued a memorandum in May 2019 directing its Occupational Safety and Health Administration staff to make every reasonable effort to collect this information during inspections and enter it into its database. About 1 percent of Labor's data on fair labor violations were missing these key company identification numbers. The nature of the willful or repeated violations for companies with DOD contracts during fiscal years 2015 through 2019 varied. According to GAO's analysis of Labor data, the most frequently found willful or repeated safety and health violations related to toxic substances and machinery. For that same time frame, the most frequently found willful or repeated fair labor violations related to failure to pay overtime. The National Defense Authorization Act for Fiscal Year 2020 included a provision for GAO to report on the number of DOD contractors that Labor found to have committed willful or repeated violations under the Occupational Safety and Health Act of 1970 (OSH Act) or the Fair Labor Standards Act of 1938 (FLSA) for fiscal years 2015 through 2019. This report examines the number of DOD contractors that were cited for willful or repeated safety, health, or fair labor standards violations under the OSH Act or FLSA, and the nature of those violations for fiscal years 2015 through 2019. GAO analyzed federal contracting data to identify companies that had defense contracts in fiscal years 2015 through 2019, and matched them to Labor data on companies cited for willful or repeated safety, health, or fair labor standards violations. In addition, GAO used the Labor data to identify information on the nature of the violations. GAO also reviewed relevant federal laws and regulations, and agency documents. For more information, contact William T. Woods at (202) 512-4841 or woodsw@gao.gov, or Thomas Costa at (202) 512-7215 or costat@gao.gov.
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  • Aviation Consumer Protection: Increased Transparency Could Help Build Confidence in DOT’s Enforcement Approach
    In U.S GAO News
    The Department of Transportation's (DOT) enforcement approach generally uses a range of methods to encourage compliance with consumer protection regulations, including conducting outreach and information-sharing, issuing guidance, and sending non-punitive warning letters for those violations that do not rise to the level that warrants a consent order. DOT usually enters into consent orders when it has evidence of systematic or egregious violations. Such orders are negotiated between DOT and violators (e.g., airlines) and typically include civil penalties. DOT officials see benefits from using consent orders, which can include credits for actions taken to benefit consumers or to improve the travel environment. Annual consent orders increased from 20 in 2008 to 62 in 2012, but then generally declined to a low of eight in 2019. GAO's analysis showed that the decline in consent orders was most marked among those issued against non-air carrier entities (e.g., travel agents), those addressing certain types of violations such as advertising, and orders containing smaller civil penalty amounts. DOT officials said that the agency did not change its enforcement practices during this time. Examples of DOT's Compliance Promotion and Enforcement Efforts Airlines and consumer advocates GAO interviewed said that DOT's enforcement process lacked transparency, including into how investigations were conducted and resolved and about when and why DOT takes enforcement actions. Moreover, DOT publishes limited information related to the results of its enforcement activities, notably information about the number and type of consumer complaints it receives as well as issued consent orders. DOT does not publish other information such as aggregated data about the number or nature of open and closed investigations or issued warning letters. DOT is taking some actions to increase transparency, such as developing a publicly available handbook, but none of those actions appears to fully address the identified information gaps such as information about the results of investigations. Some other federal agencies provide more information about enforcement activities, including publishing warning letters or data about such letters. Publishing additional information about how DOT conducts investigations and enforcement, and about the results of enforcement activities, could improve stakeholders' understanding of DOT's process and help build confidence in its approach. Consumer advocates, airlines, and other stakeholders have raised concerns about how DOT enforces aviation consumer protection requirements. DOT has the authority to enforce requirements protecting consumers against unfair and deceptive practices, discrimination on the basis of disability or other characteristics, and other harms. The FAA Reauthorization Act of 2018 contained a provision for GAO to review DOT's enforcement of consumer protection requirements. This report examines: (1) DOT's approach to the enforcement of aviation consumer protections and the results of its efforts, and (2) selected stakeholder views on this approach and steps DOT has taken to address identified concerns. GAO reviewed DOT data on consent orders and consumer complaints; reviewed other DOT documentation related to its enforcement program; interviewed DOT officials and selected industry and consumer stakeholders, including advocacy organizations, which we identified from prior work and a literature review; and identified leading practices for regulatory enforcement. GAO is making two recommendations, including: that DOT publish information describing the process it uses to enforce consumer protections, and that DOT take additional steps to provide transparency into the results of its efforts. DOT concurred with these recommendations. For more information, contact Andrew Von Ah at (202) 512-2834 or vonaha@gao.gov.
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  • Wisconsin Pain Management Companies To Settle False Claims Act Allegations
    In Crime News
    The Department of Justice announced today that Advanced Pain Management Holdings Inc. (APMH), its wholly-owned subsidiaries,  APM Wisconsin MSO (“APM MSO”) and Advanced Pain Management LLC (APM LLC); and Advanced Pain Management S.C. (APMSC) (collectively the “APM Entities”) have agreed to pay $885,452 to settle claims that they violated the False Claims Act by paying kickbacks and by performing medically unnecessary laboratory tests.  The APM Entities are headquartered in the Milwaukee, Wisconsin area. 
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  • Defense Contracting: Actions Needed to Explore Additional Opportunities to Gain Efficiencies in Acquiring Foreign Language Support
    In U.S GAO News
    What GAO FoundDOD has taken some steps to gain efficiencies in its approach to contracting for certain types of foreign language support services and products, but its contracting approach for other types remains fragmented across multiple components, and DOD has not explored whether additional opportunities exist to gain efficiencies across this broader range of contracting activity. In 2005, DOD sought to centralize and standardize contracting efforts for foreign language support by designating the Army as an executive agent to manage contracting in this area. In performing its responsibilities, the executive agent has focused its efforts solely on arranging for contracts to acquire translation and interpretation services for contingency operations because of the rapidly increasing requirements for these services. Specifically, from fiscal year 2008 through 2012, the Army, as executive agent, obligated about $5.2 billion for contracts to provide DOD components with translation and interpretation services for contingency operations. During the same time period, we found that multiple DOD components contracted independently for foreign language support outside of the executive agent's management. Specifically, to support the needs of contingency operations, predeployment training, and day-to-day military activities, we identified 159 contracting organizations in 10 different DOD components that obligated approximately $1.2 billion on contracts for foreign language support outside of those managed by the executive agent. In some cases, DOD has gained efficiencies by centralizing contracting for certain foreign language support contracts under an executive agent, but DOD has not comprehensively assessed whether additional opportunities exist to gain efficiencies across a broader range of foreign language support contracts. Best practices for service acquisition suggest that DOD's acquisition approach should provide for an agency-wide view of service contract spending and promote collaboration to leverage buying power across multiple organizations. Implementing such an approach requires an analysis of where an organization is spending its money, which should be the starting point for gaining knowledge that can assist agencies in determining which products and services warrant a more coordinated acquisition approach.8 In commenting on a draft of this report, DOD agreed with our recommendations. DOD also provided technical comments on a draft of this report, which we incorporated, where appropriate. However, DOD has not conducted an analysis of this type to evaluate the whole range of services and products that are currently managed outside the executive agent and determine whether additional efficiencies could be gained. Without a more complete understanding of where the department is spending resources on foreign language support contracts, DOD does not have all of the information it needs to make informed decisions about the types of services and products that could be managed by the executive agent and does not have reasonable assurance that it is fully leveraging its buying power for foreign language support.Why GAO Did This StudyAccording to the Department of Defense (DOD), the ability of U.S. military personnel to communicate and interact with multinational partners, security forces, and local indigenous populations can be critical factors to mission success, as evidenced by operational experiences in Afghanistan and Iraq. DOD utilizes language professionals and regional experts within its ranks of military personnel to provide foreign language support, such as foreign language skills, regional expertise, and cultural awareness capabilities needed to execute missions, as well as contracted interpreters and translators who provide this support. To meet increased demands on the need for foreign language support from ongoing contingency operations, DOD has relied on contactors to supplement the capability provided by military personnel. For example, the number of contractor personnel required to provide foreign language translation and interpretation services for contingency operations more than tripled from 2004 to 2010 (from about 4,000 to about 14,000). As of November 2012, the number of contractor personnel required by DOD was approximately 9,000. As a result, DOD has made considerable investments in providing contract support. For example, DOD obligated about $6.8 billion from fiscal years 2008 through 2012 to acquire a variety of foreign language-related services and products to support its forces.We have identified opportunities for DOD to improve its approach to contracting from a broad perspective as well as in areas related to foreign language support. For example, DOD contract management is on our list of high-risk areas in the federal government. In 2013, we noted that DOD needed to take steps to strategically manage the acquisition of services, including developing the data needed to define and measure desired outcomes to improve outcomes on the billions of dollars that DOD spends annually on goods and services. Furthermore, since 2009 we have identified a number of management challenges that DOD has faced in developing a strategic planning process to transform foreign language and regional proficiency capabilities, identifying training requirements, and reducing unnecessary overlap and duplication in foreign language and cultural awareness training products acquired by the military services.We conducted this work in response to a congressional mandate set forth in Section 21 of Public Law 111-139. That legislation requires that we identify government programs, agencies, offices, and initiatives with duplicative goals and activities and report our findings to Congress. Our objective for this report was to determine the extent to which DOD has taken steps to achieve efficiencies in its approach to contracting for foreign language support, and whether additional opportunities exist to gain further efficiencies.
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  • Department of Justice Issues Annual Report to Congress on its Work to Combat Elder Fraud and Abuse
    In Crime News
    Yesterday, the Department of Justice issued its Annual Report to Congress on Department of Justice Activities to Combat Elder Fraud and Abuse.  The report summarizes the department’s extensive efforts from July 1, 2019 through June 30, 2020.
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  • Federal Court Bars Florida Tax Preparation Businesses and Their Tax Return Preparers From Preparing Tax Returns
    In Crime News
    The Justice Department announced today that a federal court in Orlando, Florida, permanently enjoined Advanced Tax Services Inc. and Genson Financial Group LLC from preparing federal tax returns for others and ordered the businesses to disgorge $710,191.55, jointly and severally, representing the ill-gotten gains that they received for the preparation of tax returns. The court also entered permanent injunctions and disgorgement judgments against defendants Lenorris Lamoute and Dosuld Pierre, whom the court found prepared tax returns for compensation at Advanced Tax Services. The order was entered on default because the defendants failed to defend against the government’s allegations.
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  • Assistant Attorney General John C. Demers Delivers Remarks on the National Security Cyber Investigation into North Korean Operatives
    In Crime News
    Today, the Justice Department is announcing charges following a significant national security cyber investigation first disclosed publicly more than two years ago.
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  • Military Base Realignments and Closures: DOD Is Taking Steps to Mitigate Challenges but Is Not Fully Reporting Some Additional Costs
    In U.S GAO News
    The 2005 Base Realignment and Closure (BRAC) round is the fifth such round undertaken by DOD since 1988 and is the biggest, most complex, and costliest BRAC round ever. With this BRAC round, the Department of Defense (DOD) plans to execute hundreds of BRAC actions affecting over 800 defense locations, relocate over 123,000 personnel, and spend over $35 billion--an unprecedented amount, given that DOD has spent nearly $26 billion to implement the four previous BRAC rounds combined when all relevant BRAC actions have been completed. As with prior BRAC rounds, DOD is required to implement the BRAC Commission's 2005 recommendations within 6 years of their approval by the President and transmittal to Congress. Unlike with prior BRAC rounds, DOD is implementing the BRAC 2005 round during a time of conflict and significant increases to the defense budget to support ongoing contingency operations. Compounding this challenge, DOD is also implementing other extensive worldwide transformation initiatives such as the permanent relocation of about 70,000 military personnel to the United States from overseas; transformation of the Army's force structure from an organization based on divisions to more rapidly deployable, combat brigade-based units; an increase in the active-duty end strength of the Army and Marine Corps by 92,000 members; and the drawdown of combat forces from Iraq while simultaneously increasing the U.S. military presence in Afghanistan. All of these initiatives are exerting an unusually high demand on DOD's domestic facility infrastructure to accommodate new forces and existing forces being deployed or redeployed. The Office of the Secretary of Defense (OSD) at the outset of BRAC 2005 indicated its intent to reshape DOD's installations and realign DOD forces to meet defense needs for the next 20 years. Moreover, both DOD and the BRAC Commission reported that their primary consideration in making recommendations for the BRAC 2005 round was military value. As such, as opposed to simply closing bases, many of the BRAC 2005 recommendations involve complex realignments, such as designating where military forces returning to the United States from overseas bases would be located; establishing joint military medical centers; creating joint bases; and reconfiguring the defense supply, storage, and distribution network. The BRAC statute requires DOD to complete all BRAC 2005 closures and realignments by September 15, 2011. As we reported in January 2009, DOD expects almost half of the 800 defense locations implementing BRAC recommendations to complete their actions in 2011, with 230 of these 400 locations anticipating completion within the last 2 weeks before the statutory deadline. At the time of this report, DOD had only 14 months remaining until the The House Armed Services Committee report accompanying the National Defense Authorization Act for Fiscal Year 2008 directed the Comptroller General to monitor the implementation of recommendations for the 2005 round of closures and realignments of military installations made pursuant to section 2914 of the Defense Base Closure and Realignment Act of 1990. We prepared this report, our fourth, in response to the mandate, to assess (1) the challenges, if any, DOD faces in implementing BRAC recommendations and (2) DOD's efforts to mitigate any challenges and the extent to which any costs related to those mitigation efforts are being reported as BRAC implementation costs.DOD is implementing 182 BRAC recommendations for this BRAC round, but several logistical, human capital, and other implementation challenges remain. First, many locations are scheduled to complete the construction, relocation, personnel, and other actions needed to implement the recommendations within months of--and, in some cases, on--the deadline leaving little or no margin for slippage to finish constructing buildings and to move or hire the needed personnel. As of March 2010, DOD had 57 construction projects scheduled to be completed within 3 months of the statutory deadline, representing about 30 recommendations. Second, some DOD locations that involve the most costly and complex recommendations have encountered delays in awarding some construction contracts as well as experienced additional delays in the expected completion of construction. Third, DOD must synchronize the relocation of approximately 123,000 personnel with the availability of about $25 billion in new construction or renovation of facilities. Fourth, delays in interdependent recommendations are likely to have a cascading effect on the timely completion of related recommendations. These challenges have continued since our last report on BRAC implementation challenges, especially contracting and construction delays, which have further squeezed an already tight time line. The potential loss of intellectual capital is complicated by various community effects of BRAC implementation growth, such as transportation, housing, schooling, and availability of medical care. DOD is mitigating some BRAC implementation challenges, which is adding to implementation costs; however, DOD is not reporting all of these additional costs. To enhance its role in managing logistical challenges that could affect DOD's ability to achieve BRAC implementation by the statutory deadline, the military services are working with their leadership to develop solutions. Further, the military services and defense agencies are providing periodic briefings for BRAC recommendations exceeding $100 million in implementation costs, or that have significant concerns such as cost overruns or construction delays to the OSD Basing Directorate. For other BRAC recommendations, DOD is still weighing options, such as moving temporarily into different buildings while construction and renovations are completed, referred to as swing space, or accelerating the pace of construction to complete permanent facilities by the deadline, potentially incurring additional expenses. The DOD Financial Management Regulation requires the services and defense agencies to accurately capture BRAC-related costs in the annual BRAC budget justification materials submitted to Congress. Since DOD's recent fiscal year 2011 BRAC budget request--which was the final annual request for funds for the BRAC account before the statutory deadline for completion of closures and realignments--has already been submitted to Congress, such additional costs in our view may have to be funded from outside the BRAC account. However, we found that DOD's reported costs funded outside the BRAC account are not complete because the Army has not reported to Congress some of these costs as BRAC costs. Thus, OSD officials do not have full visibility over the extent of these costs funded from outside the BRAC account, given that the services prepare their own BRAC budget justification material. Until the Secretary of Defense ensures that all BRAC-related costs are captured and reported to Congress, neither congressional decision makers nor those within OSD who are charged with overseeing BRAC implementation will have a complete picture of the cost of implementing the 2005 BRAC round.
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  • Remarks by Assistant Attorney General Makan Delrahim on the Future of ASCAP and BMI Consent Decrees
    In Crime News
    Good afternoon. Thank you very much to Vanderbilt Law School and in particular to the Vanderbilt Journal of Entertainment & Technology Law for hosting this event. I love Vanderbilt and I love Nashville, and I’m sorry not to be there in person with you today. Someday when COVID-19 is a memory and social distancing is something you do only with people you don’t like, I look forward to returning to Nashville and reconnecting with many of my old friends there. More importantly, I look forward to returning to some of my favorite honky-tonks and showing off my famous dance moves. I’ve been practicing at home in my free time, to make sure I’m ready.
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  • Global Disruption of Three Terror Finance Cyber-Enabled Campaigns
    In Crime News
    The Justice Department today announced the dismantling of three terrorist financing cyber-enabled campaigns, involving the al-Qassam Brigades, Hamas’s military wing, al-Qaeda, and Islamic State of Iraq and the Levant (ISIS). This coordinated operation is detailed in three forfeiture complaints and a criminal complaint unsealed today in the District of Columbia. These actions represent the government’s largest-ever seizure of cryptocurrency in the terrorism context.
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  • Tax Cuts and Jobs Act: Future Rulemaking Should Provide Greater Detail on Paperwork Burden and Economic Effects of International Business Provisions
    In U.S GAO News
    What GAO Found GAO's interviews with officials representing eight selected U.S.-based companies revealed considerable uncertainty in how the international business provisions of Public Law 115-97—commonly known as the Tax Cuts and Jobs Act of 2017 (TCJA)—may be affecting business planning decisions. Some companies reported making specific changes, such as moving intellectual property back to the U.S. in response to a new deduction for income earned from certain foreign-derived sales of property or services attributed to assets located in the U.S. Preliminary studies on another provision taxing net income earned by foreign subsidiaries exceeding a specified threshold of certain assets hypothesized that this provision could encourage moving tangible property outside the U.S. Other business representatives emphasized the importance of nontax factors in business planning decisions, such as entering foreign markets where executives believe potential customers may be located. The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) proposed eight regulations and finalized six of them to implement four international provisions of TCJA between December 2017 and October 2020 (the most current information available at the time of GAO's review) and used guidance to supplement the regulations. The agency generally complied with legal requirements for issuing regulations and offered public comment opportunities for some guidance. However, Treasury and IRS did not fully address expectations set in government-wide guidance related to Paperwork Reduction Act (PRA) burden estimates, economic analysis requirements for regulations, and public comment on significant guidance: IRS generally did not provide specific estimates of the incremental paperwork burden of TCJA's international regulations and instead estimated the total burden for all business tax forms. The Office of Information and Regulatory Affairs' PRA guide says agencies should estimate the time and money required for an information collection. GAO's interviews with representatives of selected companies show why it is important for IRS to consider burden because representatives reported challenges, such as gathering required information from foreign subsidiaries. Anticipated economic benefits and costs of Treasury's and IRS's regulations were generally not quantified. An executive order requires agencies to provide such information to the extent feasible for regulations with the largest anticipated economic effects. As a result, Treasury and IRS made important decisions about regulations, such as whether to allow foreign military sales to be eligible for a U.S. deduction, without more specific information about the potential economic effects. IRS did not provide an opportunity for public comment before issuing revenue procedures related to TCJA's international provisions. The Office of Management and Budget identified ensuring public comment opportunities for significant guidance when appropriate as a leading practice that agencies should follow. The President recently directed a government-wide review of agency guidance processes. Why GAO Did This Study TCJA made sweeping changes to taxing U.S. corporations' international activities: (1) a transition tax on untaxed overseas earnings of foreign subsidiaries that accrued prior to 2017; (2) a tax on the net income earned by foreign subsidiaries exceeding a specified threshold of certain assets; (3) a deduction for income from certain foreign-derived sales of property or services exceeding a specified threshold of certain assets; and (4) a tax on certain payments made to a related foreign party referred to as base erosion payments. GAO was asked to review IRS's implementation of TCJA and early effects of the law. This report: (1) describes how TCJA's international provisions may be affecting U.S.-based corporations' international business activities; and (2) assesses IRS's and Treasury's development of relevant regulations and guidance to implement the provisions. GAO interviewed representatives from eight companies' tax departments randomly selected from among the 100 largest U.S.-based companies and compared relevant regulations and guidance against procedural requirements.
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