article highlighting the inequity of the tax treatment. It prompted lawmakers from both parties to try to close the so-called carried interest loophole. The on-again, off-again campaign has continued ever since.

Whenever legislation gathers momentum, the private equity industry — joined by real estate, venture capital and other sectors that rely on partnerships — has pumped up campaign contributions and dispatched top executives to Capitol Hill. One bill after another has died, generally without a vote.

One day in 2011, Gregg Polsky, then a professor of tax law at the University of North Carolina, received an out-of-the-blue email. It was from a lawyer for a former private equity executive. The executive had filed a whistle-blower claim with the I.R.S. alleging that their old firm was using illegal tactics to avoid taxes.

The whistle-blower wanted Mr. Polsky’s advice.

Mr. Polsky had previously served as the I.R.S.’s “professor in residence,” and in that role he had developed an expertise in how private equity firms’ vast profits were taxed. Back in academia, he had published a research paper detailing a little-known but pervasive industry tax-dodging technique.

$89 billion in private equity assets — as being “abusive” and a “thinly disguised way of paying the management company its quarterly paycheck.”

Apollo said in a statement that the company stopped using fee waivers in 2012 and is “not aware of any I.R.S. inquiries involving the firm’s use of fee waivers.”

floated the idea of cracking down on carried interest.

Private equity firms mobilized. Blackstone’s lobbying spending increased by nearly a third that year, to $8.5 million. (Matt Anderson, a Blackstone spokesman, said the company’s senior executives “are among the largest individual taxpayers in the country.” He wouldn’t disclose Mr. Schwarzman’s tax rate but said the firm never used fee waivers.)

Lawmakers got cold feet. The initiative fizzled.

In 2015, the Obama administration took a more modest approach. The Treasury Department issued regulations that barred certain types of especially aggressive fee waivers.

But by spelling that out, the new rules codified the legitimacy of fee waivers in general, which until that point many experts had viewed as abusive on their face.

So did his predecessor in the Obama administration, Timothy F. Geithner.

Inside the I.R.S. — which lost about one-third of its agents and officers from 2008 to 2018 — many viewed private equity’s webs of interlocking partnerships as designed to befuddle auditors and dodge taxes.

One I.R.S. agent complained that “income is pushed down so many tiers, you are never able to find out where the real problems or duplication of deductions exist,” according to a U.S. Government Accountability Office investigation of partnerships in 2014. Another agent said the purpose of large partnerships seemed to be making “it difficult to identify income sources and tax shelters.”

The Times reviewed 10 years of annual reports filed by the five largest publicly traded private equity firms. They contained no trace of the firms ever having to pay the I.R.S. extra money, and they referred to only minor audits that they said were unlikely to affect their finances.

Current and former I.R.S. officials said in interviews that such audits generally involved issues like firms’ accounting for travel costs, rather than major reckonings over their taxable profits. The officials said they were unaware of any recent significant audits of private equity firms.

For a while, it looked as if there would be an exception to this general rule: the I.R.S.’s reviews of the fee waivers spurred by the whistle-blower claims. But it soon became clear that the effort lacked teeth.

Kat Gregor, a tax lawyer at the law firm Ropes & Gray, said the I.R.S. had challenged fee waivers used by four of her clients, whom she wouldn’t identify. The auditors struck her as untrained in the thicket of tax laws governing partnerships.

“It’s the equivalent of picking someone who was used to conducting an interview in English and tell them to go do it in Spanish,” Ms. Gregor said.

The audits of her clients wrapped up in late 2019. None owed any money.

As a presidential candidate, Mr. Trump vowed to “eliminate the carried interest deduction, well-known deduction, and other special-interest loopholes that have been so good for Wall Street investors, and for people like me, but unfair to American workers.”

wanted to close the loophole, congressional Republicans resisted. Instead, they embraced a much milder measure: requiring private equity officials to hold their investments for at least three years before reaping preferential tax treatment on their carried interests. Steven Mnuchin, the Treasury secretary, who had previously run an investment partnership, signed off.

McKinsey, typically holds investments for more than five years. The measure, part of a $1.5 trillion package of tax cuts, was projected to generate $1 billion in revenue over a decade.

credited Mr. Mnuchin, hailing him as “an all-star.”

Mr. Fleischer, who a decade earlier had raised alarms about carried interest, said the measure “was structured by industry to appear to do something while affecting as few as possible.”

Months later, Mr. Callas joined the law and lobbying firm Steptoe & Johnson. The private equity giant Carlyle is one of his biggest clients.

It took the Treasury Department more than two years to propose rules spelling out the fine print of the 2017 law. The Treasury’s suggested language was strict. One proposal would have empowered I.R.S. auditors to more closely examine internal transactions that private equity firms might use to get around the law’s three-year holding period.

The industry, so happy with the tepid 2017 law, was up in arms over the tough rules the Treasury’s staff was now proposing. In a letter in October 2020, the American Investment Council, led by Drew Maloney, a former aide to Mr. Mnuchin, noted how private equity had invested in hundreds of companies during the coronavirus pandemic and said the Treasury’s overzealous approach would harm the industry.

The rules were the responsibility of Treasury’s top tax official, David Kautter. He previously was the national tax director at EY, formerly Ernst & Young, when the firm was marketing illegal tax shelters that led to a federal criminal investigation and a $123 million settlement. (Mr. Kautter has denied being involved with selling the shelters but has expressed regret about not speaking up about them.)

On his watch at Treasury, the rules under development began getting softer, including when it came to the three-year holding period.

Monte Jackel, a former I.R.S. attorney who worked on the original version of the proposed regulations.

Mr. Mnuchin, back in the private sector, is starting an investment fund that could benefit from his department’s weaker rules.

Even during the pandemic, the charmed march of private equity continued.

The top five publicly traded firms reported net profits last year of $8.6 billion. They paid their executives $8.3 billion. In addition to Mr. Schwarzman’s $610 million, the co-founders of KKR each made about $90 million, and Apollo’s Leon Black received $211 million, according to Equilar, an executive compensation consulting firm.

now advising clients on techniques to circumvent the three-year holding period.

The most popular is known as a “carry waiver.” It enables private equity managers to hold their carried interests for less than three years without paying higher tax rates. The technique is complicated, but it involves temporarily moving money into other investment vehicles. That provides the industry with greater flexibility to buy and sell things whenever it wants, without triggering a higher tax rate.

Private equity firms don’t broadcast this. But there are clues. In a recent presentation to a Pennsylvania retirement system by Hellman & Friedman, the California private equity giant included a string of disclaimers in small font. The last one flagged the firm’s use of carry waivers.

The Biden administration is negotiating its tax overhaul agenda with Republicans, who have aired advertisements attacking the proposal to increase the I.R.S.’s budget. The White House is already backing down from some of its most ambitious proposals.

Even if the agency’s budget were significantly expanded, veterans of the I.R.S. doubt it would make much difference when it comes to scrutinizing complex partnerships.

“If the I.R.S. started staffing up now, it would take them at least a decade to catch up,” Mr. Jackel said. “They don’t have enough I.R.S. agents with enough knowledge to know what they are looking at. They are so grossly overmatched it’s not funny.”

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How Long Should It Take to Give Away Millions?

Ms. Madoff and others pushing for change see a growing gap between reputation-burnishing promises of money and distributions to people who need it. The Giving Pledge, which was started by Bill Gates, Melinda French Gates and their friend and collaborator Warren E. Buffett, gave billionaires a space where they could announce their intention to give away half their fortunes or more, often to great acclaim. But it provides no mechanism to monitor or ensure the giving actually happens.

Earlier this year, the Chronicle of Philanthropy ranked Jeffrey P. Bezos, the founder of Amazon, as the top philanthropist of 2020 because he committed $10 billion to his Bezos Earth Fund to fight climate change. But he had handed out less than one-tenth of that, $791 million, to working nonprofits like the Environmental Defense Fund and Natural Resources Defense Council.

Charitable giving has remained relatively steady for decades, clocking in at roughly 2 percent of disposable income per year, give or take a few tenths of a percent. In 1991, the year that Fidelity began to offer donor-advised funds, just 5 percent of giving went to foundations and DAFs. By 2019, the most recent year available, that figure had risen to 28 percent.

It was January 2020 when that small group gathered at the offices of the nonprofit consulting firm the Bridgespan Group in Manhattan for a wonky brainstorming session about the state of philanthropy. The group included foundation leaders, former congressional staff members, former senior Internal Revenue Service officials and a key constituency in any effort to change how billionaires give away their money: billionaires.

One of the organizers was John D. Arnold. Once a trader at Enron, the Houston energy company that infamously collapsed in 2001, Mr. Arnold later ran his own hedge fund, which made him one of the youngest billionaires in the United States.

Ms. Madoff, another leader of the initiative, has written a book, “Immortality and the Law,” about the growing legal power of dead people in America and has applied her knowledge of estate taxes and inheritance law to the rising field of philanthropy.

The group focused on the fact that most of the laws governing philanthropy were half a century old, dating back to 1969.

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Treasury Defends Plan to Narrow Tax Gap by Hiring More I.R.S. Agents

The Biden administration on Thursday defended its assessment that it could raise $700 billion in revenue by pumping money into the Internal Revenue Service to beef up its enforcement capabilities amid criticism that its projections were overly rosy.

The Treasury Department released a 22-page report laying out the administration’s new “tax compliance agenda,” which is a centerpiece of its plans to pay for a $1.8 trillion infrastructure and jobs proposal. The Biden administration wants to give the I.R.S. $80 billion over the next decade so that it can overhaul its outdated technology and ramp up audits of wealthy taxpayers and corporations.

The Biden administration’s estimates of the return on investment that it could generate from boosting the I.R.S. budget far surpassed projections by the nonpartisan Congressional Budget Office. And John Koskinen, a former I.R.S. commissioner under President Barack Obama and President Donald J. Trump, has suggested that it would be hard for the cash-strapped agency to efficiently spend that much money.

The Treasury Department said that it believes its projections are conservative. Much of the revenue from more rigid enforcement would become evident in the later part of the decade, the report said, but Treasury officials believe that with more enforcement staff and better technology the I.R.S. can chip away at the “tax gap.”

$1 trillion owed to the government is not being collected every year. The Treasury Department estimated on Thursday that in 2019 the tax gap was $584 billion and is on pace to total $7 trillion over the next 10 years.

The Treasury report said that much of the revenue it estimates would come through its “information reporting” rules for financial institutions. This would give the I.R.S. more visibility into corporate accounts to determine how much money they are actually taking in and what should be taxed. The department said it expects that such reporting would be helpful for audits and would serve as a deterrent against corporate tax evasion.

The new information reporting rules would also include an effort by the Biden administration to bring cryptocurrencies into the tax regime and to crack down on those using cryptocurrencies to avoid paying taxes. The report said that cryptocurrency exchange accounts and payment accounts that accept them would fall under the reporting rules. Businesses that receive cryptoassets with a fair market value of more than $10,000 would be subject to information reporting.

The Biden administration has faced questions from Republican lawmakers, such as Senator Mike Crapo of Idaho, to justify its claims that giving the I.R.S. so much money will yield such robust returns. Conservative political groups have criticized the Biden administration plan to hire an army of I.R.S. agents, saying it’s a way to hike taxes.

The Treasury report attempted to rebut such claims, noting that increased audits would be focused on the rich.

“It is important to note that the President’s compliance proposals are designed to ameliorate existing inequities by focusing on high-end evasion,” the report said. “Audit rates will not rise relative to recent years for those with less than $400,000 in actual income.”

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Investors Put Millions Into a Luxury Student Dorm. They Say They Were Ripped Off.

Ms. Martinez, who lives not far from the dorm, said she had invested a little over $100,000 in the deal — money that came from the sale of a rental property. Like many investors in Skyloft, she was looking for a way to defer paying capital gains on the prior sale, and the private placement was marketed by brokers as a “1031 exchange” deal that would keep the Internal Revenue Service at bay.

A 1031 exchange deal, named after a section of the federal tax code, allows an investor to defer paying capital gains on the sale of property as long as the proceeds are invested into another property of equal or greater value to the one sold. These transactions are often criticized as a tax break for the rich, but the deals have also long attracted interest from investors of more moderate means.

The Biden administration is considering eliminating many of these deals as a way to raise additional revenue to pay for increased spending on child care and family leave programs. The Biden plan would allow 1031 exchanges to continue for most investors seeking to defer up to $500,000 in capital gains — many in the Skyloft deal fit that bill.

In recent years, student housing projects like Skyloft have become especially attractive real estate investments — especially as universities have encouraged the building of luxury apartment buildings to cater to students from wealthy families. Before the pandemic, there were, on average, $7 billion in student housing transactions in the United States each year. That was up from $3 billion just a decade ago, according to CBRE, a commercial real estate services firm.

Court filings and interviews with investors set out how the Skyloft project financing worked. To secure the $124 million purchase of Skyloft, Nelson Partners obtained a $66 million mortgage from a group of lenders led by UBS, in addition to the $75 million raised from ordinary investors. It also got $35 million in short-term financing from Axonic Capital, a New York hedge fund that specializes in commercial real estate transactions. The loan from Axonic was used to complete the purchase while Nelson Partners was raising money from investors.

Nelson Partners was to pay Axonic back the bridge loan, plus interest, using money raised from investors like Ms. Martinez. But Mr. Nelson’s firm did not pay back the loan, according to court filings. In February 2020, Axonic put Nelson Partners on notice, and it notified him last May that it was declaring Nelson Partners in default and taking control of the building.

Mr. Nelson opposed Axonic’s move but did not inform investors about his dealings with the hedge fund, according to the lawsuits. Instead, in April 2020, Nelson Partners stopped paying monthly cash dividends to the investors, telling them that it needed to conserve cash during the pandemic in the event students and their parents stopped paying rent. Mr. Nelson’s firm also received a loan of just over $1.2 million from the Small Business Administration’s Paycheck Protection Program.

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Tax Day 2021: Here’s What You Need to Know

It’s May 17 and it’s Tax Day, the deadline for filing your 2020 taxes. The Internal Revenue Service in March said that Americans who needed it could take extra time to file their taxes. That time has arrived.

The one-month delay from the usual April deadline did not offer as much extra time as the I.R.S. gave people last year, when the filing deadline was pushed to July 15. But the aim was the same: to make it easier for taxpayers to get a handle on their finances — as well as tax changes that took effect this year with the signing of the American Rescue Plan.

Still have questions? Here are some articles that might help.

How the Pandemic Has Changed Your Taxes

New rules for a new reality, from stimulus payments to retirement withdrawals to unemployment insurance, could cut your bill or even generate extra refunds.

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Michael Jackson’s Estate Is Winner in Tax Judge’s Ruling

After Michael Jackson died in 2009, at age 50, the executors of his estate began shoring up the shaky finances of the onetime King of Pop, settling debts and striking new entertainment and merchandising deals. Before long the estate was in strong shape, with debts reduced and millions of dollars in earnings.

But there was another matter that has taken more than seven years to litigate: Jackson’s tax bill with the Internal Revenue Service, in which the government and the estate held vastly different views about what Jackson’s name and likeness were worth when he died.

The I.R.S. thought they were worth $161 million. The estate put it at just $2,105 — arguing that Jackson’s reputation was in tatters at the end of his life, after years of lurid reporting on his eccentric lifestyle and a widely covered trial on child molestation charges, in which Jackson was acquitted.

On Monday, in a closely watched case that may have implications for other celebrity estates, Judge Mark V. Holmes of United States Tax Court ruled that Jackson’s name and likeness were worth $4.2 million, rejecting many of the I.R.S.’s arguments. The decision will significantly lower the estate’s tax burden from the government’s first assessment.

$48 million.

But the tax case turned on the value of Jackson’s public image at the time of his death. His reputation had been badly damaged, and since 1993, Judge Holmes noted, Jackson had no endorsements or merchandise deals unrelated to a musical tour or album.

Yet the judge found that the estate’s estimate of $2,105 was just too low and that the estate was “valuing the image and likeness of one of the best known celebrities in the world — the King of Pop — at the price of a heavily used 20-year-old Honda Civic” (complete with a footnote citation to a used car price guide).

In a 271-page ruling dotted with literary references to Hemingway and Plutarch, Judge Holmes — who is noted for his clear and sometimes humorous writing style summarizing dense tax cases — summed up the vicissitudes of Jackson’s life, public reputation and finances.

$750 million to buy out its share of that catalog.)

The Jackson case has been watched closely as a guide for how celebrity estates may be valued, and for their tax liabilities. Among the major estates with large tax issues still before the I.R.S. are those of Prince and Aretha Franklin.

In a statement, John Branca and John McClain, co-executors of the Jackson estate, called the decision “a huge, unambiguous victory for Michael Jackson’s children.”

“For nearly 12 years Michael’s estate has maintained that the government’s valuation of Michael’s assets on the day he passed away was outrageous and unfair, one that would have saddled his heirs with an oppressive tax liability of more than $700 million,” Branca and McClain said. “While we disagree with some portions of the decision, we believe it clearly exposes how unreasonable the I.R.S. valuation was and provides a path forward to finally resolve this case in a fair and just manner.”

The I.R.S. did not immediately respond to a request for comment on Monday night.

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The Bureaucrat From Buffalo Who Pushed Somalia to the Brink

NAIROBI, Kenya — During his years as an administrator at the Department of Transportation in upstate New York, the Somali refugee turned American citizen took classes in political science, imbibing democratic values he hoped to one day export back to his homeland.

That dream came true for Mohamed Abdullahi Mohamed in 2017, when he returned to Somalia and was elected president in a surprise victory that evinced high hopes he might reform — even transform — his dysfunctional, war-weary country.

But those aspirations have crumbled since Mr. Mohamed failed to hold elections when his four-year term ended in February, then moved to extend his rule by two years — a step many Somalis viewed as a naked power grab.

A furious political dispute turned violent on Sunday when a series of gunfights broke out between rival military factions in the capital, Mogadishu, evoking fears that Somalia, after years of modest yet gradual progress, could descend into the kind of clan-based bloodshed that ripped it apart in the 1990s.

young Somalis determined to find a better future and progress in the fight against insurgents with Al Shabab, one of the world’s best organized and funded Al Qaeda affiliates.

Mr. Mohamed did not respond to a request for an interview or to questions sent to his aides.

Popularly known as “Farmaajo” — a derivation of the Italian word for cheese and purportedly his father’s favorite food — Mr. Mohamed was once the bearer of many Somalis’ hopes.

Mr. Mohamed was widely seen as less corrupt, more reform-oriented and less manipulated by foreign interests than the other 24 candidates.

“This is the beginning of unity for the Somali nation,” Mr. Mohamed told supporters shortly after winning the election.

Mr. Mohamed came to the United States in 1985 as a junior diplomat at the Somali Embassy and, as his country tumbled into conflict, decided to stay. A family friend said he first applied for political asylum in Canada, where his mother and siblings lived, and later obtained a Canadian passport.

But in the early 1990s, Mr. Mohamed, newly married, moved back to the United States where his family eventually settled in Grand Island, next to Buffalo and Niagara Falls.

back at his desk at the Department of Transportation in Buffalo, where he enforced nondiscrimination and affirmative action policies.

The great hopes many Somalis invested in Mr. Mohamed in 2017, when he won the presidency against all expectations, stemmed partly from his public image as a calm and bespectacled, if somewhat uncharismatic, technocrat. But disappointment soon set in.

human rights groups, United Nations and Western officials.

Mr. Yasin, a former journalist with Al Jazeera, had become a conduit for unofficial Qatari funds that were used to help get Mr. Mohamed elected, and which he used to solidify his political base while in power, the officials said — part of a wider proxy battle for influence between rival oil-wealthy Persian Gulf states in the strategically located country.

Some in Mr. Mohamed’s inner circle, including Colonel Sheikh, grew disillusioned and quit. “I said to myself: ‘These people are bad news,’” he said.

In 2019, Mr. Mohamed gave up his American citizenship. He didn’t explain the decision, but officials familiar with the matter pointed to one possible factor.

At the time Mr. Mohamed surrendered his passport, his finances had come under investigation by the Internal Revenue Service in the United States, said three Western officials familiar with the matter, speaking on the condition of anonymity to discuss a sensitive matter about a foreign head of state.

cutting ties with neighboring Kenya in December as part of a long-running diplomatic dispute.

allying with the autocratic president of Eritrea, Isaias Afwerki, whose military has trained thousands of Somali troops, Western and Somali officials say.

“It comes as cash and it’s uncounted,” Abdirizak Mohamed, a former interior minister and now opposition lawmaker, said of the Qatari funds. “It’s an open secret.”

Now Mr. Mohamed is confined to Villa Somalia, the presidential compound in central Mogadishu, as military units loyal to his most powerful opponents — a coalition of presidential candidates and the leaders of two of Somalia’s five regional states — camp on a major junction a few hundred yards away.

Worried residents say they don’t know whether the president’s latest concession will offer a genuine opportunity for new talks, or a pause before rival fighters open fire again.

“I feel a lot of fear,” said Zahra Qorane Omar, a community organizer, by phone from Mogadishu. “We’ve gone through enough suffering. The bullet is not what this city or its people deserve.”

Hussein Mohamed contributed reporting from Mogadishu, Somalia.

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Biden’s $4 Trillion Economic Plan, in One Chart

Most of the spending and tax cuts in Wednesday’s proposal is directed at families, with provisions for a national paid family and medical leave program; child care subsidies; and extensions of several tax credit expansions from the most recent Covid-19 relief law.

Newly proposed education spending includes universal prekindergarten for 3- and 4-year-olds; two years of free community college; an increase in the maximum Pell Grant award; and investments in colleges and universities serving minority groups.

The plan also calls on Congress to adjust the unemployment insurance system so that it would automatically link the length and amount of benefits to economic conditions.

The president intends to pay for the infrastructure portion of the plan with 15 years of higher taxes on corporations.

give more money and enforcement power to the Internal Revenue Service to crack down on tax evasion.

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Biden Seeks $80 Billion to Beef Up I.R.S. Audits of High-Earners

WASHINGTON — President Biden, in an effort to pay for his ambitious economic agenda, is expected to propose giving the Internal Revenue Service an extra $80 billion and more authority over the next 10 years to help crack down on tax evasion by high-earners and large corporations, according to two people familiar with the plan.

The additional money and enforcement power will accompany new disclosure requirements for people who own businesses that are not organized as corporations and for other wealthy people who could be hiding income from the government.

The Biden administration will portray those efforts — coupled with new taxes it is proposing on corporations and the rich — as a way to level the tax playing field between typical American workers and very high-earners who employ sophisticated efforts to minimize or avoid taxation.

Mr. Biden plans to use money raised by the effort to help pay for the cost of his “American Families Plan,” which he will detail before addressing a joint session of Congress on Wednesday.

$2.3 trillion infrastructure package, is expected to cost at least $1.5 trillion and will include universal prekindergarten, a federal paid leave program, efforts to make child care more affordable, free community college for all and tax credits meant to fight poverty.

The administration also aims to pay for the plan by raising the top marginal income tax rate for wealthy Americans to 39.6 percent from 37 percent and raising capital gains tax rates for those who earn more than $1 million a year. Mr. Biden will also seek to raise the tax rate on income that people earning more than $1 million per year receive through stock dividends, according to a person familiar with the proposal.

Administration officials have privately concluded that an aggressive crackdown on tax avoidance by corporations and the rich could raise at least $700 billion on net over 10 years. The $80 billion in proposed funding would be an increase of two-thirds over the agency’s entire funding levels for the past decade.

The administration is expected to portray the $780 billion it expects to collect through enhanced enforcement as conservative. That figure includes only money directly raised by enhanced tax audits and additional reporting requirements, and not any additional revenue from people or companies choosing to pay more taxes after previously avoiding them.

Previous administrations have long talked about trying to close the so-called tax gap — the amount of money that taxpayers owe but that is not collected each year. This month, the head of the I.R.S., Charles Rettig, told a Senate committee that the agency lacked the resources to catch tax cheats, costing the government as much as $1 trillion a year. The agency’s funding has failed to keep pace with inflation in recent years, amid budget tightening efforts, and its audits of rich taxpayers have declined.

whose research with the Harvard University economist Lawrence H. Summers suggests that the United States could raise as much as $1.1 trillion over a decade via increased tax enforcement.

Mr. Summers praised Mr. Biden’s expected plan in an email late Monday. “This is the broadly right approach,” he said. “Deterioration in I.R.S. enforcement effort and information gathering is scandalous. The Biden plan would make the American tax system fairer, more efficient and, I’m confident, raise more revenue than official scorekeepers now forecast — likely a trillion over 10 years.”

Mr. Biden’s efforts would incorporate some of Ms. Sarin and Mr. Summers’s suggestions, including investing heavily in information technology improvements to help the agency better target its audits of high-earners and companies.

They would also provide a dedicated funding stream to the agency, to enable officials to steadily ramp up their enforcement practices without fear of budget cuts, and to signal to potential tax evaders that the agency’s efforts will not be soon diminished. Mr. Biden would also add new requirements for people who own so-called pass-through corporations or hold their wealth in opaque structures, reminiscent of a program established under President Barack Obama that helps the agency better track possible tax evasion by Americans with overseas holdings.

Fred T. Goldberg Jr., an I.R.S. commissioner under President George H.W. Bush, called Mr. Biden’s plan “transformative” for combining those efforts.

“Information reporting, coupled with restoring enforcement efforts, is key to improve in compliance,” Mr. Goldberg said in an email. “Audits alone will never do the trick.”

He added: “None of this happens overnight. A decade of stable funding is necessary to recruit and train talent and build on the necessary technology — not only for compliance purposes but to meet the quality of services that the vast majority complaint taxpayers expect and deserve.”

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