Accounting
Women in accounting: Progress, but far from perfection
While accounting firms have made progress in advancing more women into leadership positions in recent years, female professionals are still not being promoted at the same rate as their male counterparts — and those that have reached the top of the ladder often had to invest extra effort in the ascent.
Or, as Kimberly Ellison-Taylor put it, they have to be Iron Women.
With the caveat that women are not a monolithic group, Ellison-Taylor, former chair of the American Institute of CPAs’ National Commission on Diversity and Inclusion and CEO of consultancy KET Solutions, explained, “I have met women who say, ‘Oh I didn’t need the ERG [employee resource group] for women, you know, and I got through it on my own.’ Yeah, but you got through it because you were an Olympian. Should it be required that you’re an Olympian?”
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“You can’t just be a great athlete,” she continued. “You had to be in an Iron Man contest in order to get ahead as a woman. Because yes, I know plenty of women who will recount their stories of basically, in another way of saying it, they walked nine miles with no shoes on up and down a hill in snow with nine books under each arm. Yes, they did it. But is that what we want for our daughters? No.”
While more women are seated at the executive tables of CPA firms these days, the number of leaders still doesn’t match the gender ratio across all accountants.
Bonnie Buol Ruszczyk, founder of BBR Cos. and president of the Accounting MOVE Project, which produces an annual survey on workplace demographics in the profession to drive greater inclusion, noted the stagnation: “Based on what I’m seeing — and we just closed the 2025 Accounting MOVE Project survey so that data isn’t available yet — but I’m not seeing huge shifts,” she said. “While women still make up a majority of firm employees overall — I’ve seen percentages between 53 and 60% — they make up far less of partner groups or firm leadership.”
(Read more: See our 2025 Best Firms for Women list.)
The average ratio of women partners is still below 30%, according to Ruszczyk, who explained “31% is a tipping point because there’s studies out there that show that that’s kind of the point where people are seen as individuals versus a group of others.”
“I would think we’d have higher percentages of women, though, just statistically if we’re coming in at a higher concentration, in some cases, than men and now in the newer classes of accounting grads,” said Ellison-Taylor. “Why aren’t we staying and what can the firm do in order to help?”
Why are so many women not getting promoted, or even leaving firms before promotion is a possibility? Ruszczyk echoed Ellison-Taylor’s point about women attempting to fit a trajectory or model for leadership that was not exactly crafted with them in mind: “I think one of the things that doesn’t get talked about as much is there are really smart, talented women out there that look at the role of partner the way it is currently fashioned at a lot of firms and go, ‘I don’t feel like I can give 100% to that. So, I’m not [going to] do it,'” she explained.
Additionally, there might not be enough women in leadership positions to pave the way and cultivate a more inclusive culture.
“We all know the stats, that when you have more diversity around the table that you can eliminate blind spots,” said Arianna Campbell, chief operating officer at Boomer Consulting. “If you look at any homogeneous group, there are going to be blind spots. So when you can have more women, not just at the partner seat at the table, but at whatever the important seat is at the table, that’s going to help you to identify the blind spots and then work to address them. Because I would also say it’s not one size fits all for firms, so I don’t think it’s a checklist of just: Do these things. I think that different firms have different cultures. And so that’s why it’s important to understand, for your firm specifically, where maybe some of those more stubborn roadblocks are. But you’ve got to invite other voices to have a seat at the table.”
The women who do attain high-level roles are celebrated, as are the firms that enable their ascension, including those on Accounting Today’s Best Firms for Women list, which have greater parity in female leadership than many of their peers. Of course, not every woman wants the partner path, and firms need to offer options that work for everyone on an individual basis. And to understand that, firms and firm leaders need to listen.
Listen and learn
When asked how firms can improve the numbers she tracks through her benchmarking work, specifically in retaining and advancing women, Ruszczyk responded: “Start by asking the women at your firm! We are not a monolith, and your women will be able to tell you what is important to them specifically.”
Once that is ascertained, firms must continue the conversation, bearing in mind that circumstances and priorities change — and not just with women but everyone at the firm.
Asked what firms could do better in fostering women-empowering workplaces, Sarah Elliott, executive leadership coach, consultant and co-founder of leadership development firm Intend2Lead, pinpointed “making assumptions about where a woman’s at or what she wants without having the active conversations.”
“I think not revisiting whatever conversations were had,” she continued. “We all change over time, right? Our circumstances and situations change. So what was true for someone a year ago may not be true today. So I think it’s important to actively have those conversations, let those conversations evolve, and not make assumptions for other people about what they want or don’t want.”
One of the things routinely mentioned in that latter column of what women want is mentorship and coaching — but that must also come with a healthy dose of open communication, said Ellison-Taylor. “Our career coaches have to be more intentional,” she explained. “And that means really helping me develop a career plan, a success plan. Give it to me straight: If I aspire to be a partner or a principal or a senior director, what is it that I need? What are the competencies that I need to master in order to do it? And at the same time, if there are things I can improve, then I need the resources that will help me improve those things. And I think some of it is going to be tough love.”
“Tough love” is part of the “harder feedback that builds character that helps them for the next leadership role,” she continued, adding: “I just don’t think feedback should be a surprise. I think there’s an appropriate way to give feedback. We could do a whole session on how do you give feedback, because I think people don’t do it well.”
Campbell also offered a recommendation for more honest feedback and transparency firmwide: “One of my favorite ways to do it is focus groups, and keeping them kind of smaller, no more than four to five people,” she shared. “And it could be by level. It could be cross-functional. But giving women a space to be able to share what their perspective is. But I also think it’s important, if you have the opportunity, to have integrated groups of women and men, or hear things from the men’s perspective as well, because, remember, it’s just not a conversation where women should have to carry the burden of sharing their perspective because they’re living that perspective.”
Salary is another area firms can improve to better recruit, retain and advance women.
“Start by fixing what candidates notice first: culture and pay,” said Ruszczyk. “Nothing signals seriousness like equal pay for equal work, so run real pay-equity audits and close gaps.”
An inclusive environment is dependent on this kind of openness around roles and compensation, Ruszczyk stressed. “I think we need to have transparency in interviews, I think we need it in promotions,” she said. “We need it in mentorship programs, sponsorship programs. I mean, pay equity, transparency, all of that is important to not just showing that the firm is really making a concerted effort to create an inclusive environment, but it also allows people to know how things are measured so they know what is expected of them.”
Additionally, firms should be able to answer some simple questions that get to the heart of supporting more female leaders in accounting.
“One of the questions that I used to always ask [firms] is, ‘What would it take to have a woman managing partner? What would it take?'” said Ellison-Taylor. “It’s interesting — if a firm can’t articulate it, that means the path is ambiguous, nebulous and vapor. If they can say you’ve got to do this, this, this and this, and it mirrors what the other people have been doing, then I think, OK, so maybe they really have a vision of what that could look like. Because I don’t know any women that want tokenism. I don’t know any women who want roles just because we’re women.”
Flexibility for all
Flexibility is always a large predicting factor for firms landing on Accounting Today’s annual Best Firms to Work For list, and especially the Best Firms for Women. Women are more often operating in caregiving roles, which makes policies like remote and hybrid work and family-related benefits especially crucial.
“Build flexibility into how work gets done, predictable staffing, protected PTO, outcome-based performance, and make sure leaders can succeed from hybrid or remote seats,” advised Ruszczyk. “Just as important, move opportunity onto the clock. If networking and training always happen after hours, caregivers are shut out. Offer daytime options, virtual access, and childcare support so talent isn’t filtered by life stage.”
These policies should also not be filtered by gender, as the entire workforce benefits, Ruszczyk continued, mentioning an anecdotal story of a mother being able to slightly shift her hours to pick up a child from school. “You know, it’s not even enormous flexibility that they’re looking for,” she said. “It’s just a little bit of that. And a lot of firms do offer that. A lot of the firms I talked to are offering that, and are certainly looking at opportunities for that. Small things like that can make an enormous difference. And it’s not just for women. I mean, honestly, what’s good for women is good for everybody.”
Campbell shared the same sentiment: “What’s good for women is good for everyone, because men want flexibility as well. When you think about different age groups, they want flexibility; it’s not just the young people that want flexibility — it’s across the board.”
What’s good for women is good for everyone — and good for business.
“Firms that really focus on belonging, creating a sense of belonging and connection for their people,” Intend2Lead’s Elliott identified as the hallmarks of firms that successfully support women. “And that’s not about women, that’s just good business practice. So really investing in, ‘What are our firm values? Is that a value for us? Are we talking about that? Are we modeling that? Are we actually developing our people to have those skills?’ Because those are skills. They aren’t just something we say we do. Some of the firms we work with, they invest in training around creating belonging and psychological safety.”
Ellison-Taylor put an even finer point on the business case for advancing women. “There’s no way that a firm, if they had different service lines, would just let one of their service lines flounder,” she said. “They would figure out how to increase the productivity. And I think firms need to think of this the same way. This is a resource that may not be progressing at the same pace as your other resources. So, what are you going to do to ensure that everyone has an opportunity to thrive and grow?”
This “resource” is also crucial to client relationships and success.
“Even if you didn’t do it for your own team, you have clients that are women,” she said. “And if you don’t understand women in your own workforce, you certainly aren’t going to understand them in the marketplace, and you’re going to lose opportunities because you’re going to miss the boat with your women decision-makers in your various clients. So, I think that firms should take a look at their ERGs, evaluate the wording, evaluate the programming content, ensure that it’s inclusive, and that it’s open to everyone who wants to come, and then continue to have these topics that talk about the why, so that people aren’t thinking that you’re doing it purely on the basis of gender.”
Ellison-Taylor shared that as a member of the women’s initiative executive committee, “We have had managing partners or CEOs, as a member of that committee, who do not miss the meetings because they so appreciate learning about women. And every year I know the AICPA has tried to get men to come to the global Women’s Summit because they want men to realize it’s not a conference for women. It’s a conference about women and we want men to be a part of that conversation. And to the extent that they show up and lead from the front, attend the women’s ERG events, show everybody that you’re attending. That goes a long way to modeling the behavior that we want to replicate inside the firm.”
Adding allies
Speaking to her experience at these kinds of events, Ellison-Taylor also mentioned the importance of men stepping up as advocates to ensure more women’s voices are heard. “Firms that look around their table, and they say, ‘Who’s missing?’ Who is willing to ask the uncomfortable question of who’s missing? There have been partners who have been invited to speak on stage who have said no if they saw that there were no women on the stage. They were allies in support. I mean, from managing partners and regular line partners I have seen them firsthand say, ‘Where are the women?'”
Men can also be allies in a mentorship capacity, explained Elliott. “With mentoring women, are men actively seeking to advocate for and mentor women?” she asked. “Because oftentimes it’s easy for them to gravitate to mentoring other men because it’s more comfortable or they’re more like them. So I think sometimes there can be a gap there. So intentionally seeking out those mentorship opportunities — are they including women? And when I say including, I’m thinking of all these things that we do without thinking about it, right? We tend to gravitate to people like us even for social events. The way we talk to one another, are we actually thinking about who may feel excluded from that group and are we creating a sense of belonging for others who may be different from us? … Are they being actively included and made to feel comfortable and safe in that space so that they can share their ideas and opinions?”
Ellison-Taylor benefitted from male colleagues championing her, and women as a whole. “That’s what I’ve had in my career, men who pushed me who said, ‘You’re ready. It’s time. You’ve been in this role too long, it’s time,'” she shared. “‘You need to go and do some other things.’ That’s what I have appreciated. And when I’ve seen firms do it, it has made a world of difference.”
Women need this kind of advocacy not only from firm leaders and both male and female colleagues — but also from within.
“There’s lots of writing out there about how women see a job description and they need to be, you know, 90 to 100% qualified, and men see a job description and they’re like, ‘Yeah, I got 30% of that. I’m cool.’ So that kind of comes into play,” shared Ruszczyk.
Ellison-Taylor has experienced the same: “We’re harder on ourselves generally than anyone else ever could be,” she said. “We will hold back until we are overqualified for the role.”
While all women can benefit from a boost, that’s even more clear for women of color, said Ellison-Taylor. “Women of color are not doing as well as our Caucasian colleagues,” she said. “And that is a whole other dilemma in and of itself. As a leader, if I looked at my resource pool and people were coming in, but they weren’t staying at higher percentages than anyone else or they were not progressing and getting promoted, I would ask why. Now, I know that shrinking margins and failure are usually the parents of change. So, when we’re successful — and as a profession, we’re very successful — I get that we don’t ask those hard, uncomfortable questions because we don’t need to. But as a leader who leads people, and if you care about your people, then we should care that everyone’s not progressing and that there are people missing from this conversation because the conversation about women absolutely includes women of color, and we are missing from those tables.”
Diversity is also an imperative to firms’ younger staff. “Representation matters too,” Ruszczyk said. “If candidates don’t see women on a firm’s leadership team, they read that as a ceiling. Gen Z is explicit about this. Studies including ManpowerGroup’s ‘The New Human Age’ show many won’t join firms without diverse leadership, and they’ll leave if progress stalls.”
The decline of DEI?
On the flip side, women’s initiatives and programs are in danger of stalling in the face of the diversity, equity and inclusion backlash in corporate America.
“I do worry about this anti-DEI sentiment, and I expect the politicization of inclusion will negatively impact women,” Ruszczyk shared. “Much of the ‘bring back meritocracy’ talk is code for restoring the default that advantaged white men. Most people, regardless of who they are or what they look like, would embrace a meritocracy that used transparent criteria, audited processes, and bias checks.”
Ellison-Taylor is sensing the same. “I think there is absolutely a backlash against DEI,” she said. “I think there is not a full understanding about what it means and what it doesn’t mean. I think that there were certainly improvements … . You can always tweak and edit and update a program … . I do think that the consequences of the decisions that are being made today will be playing out for years and years to come unless we can figure out a way to scale our programs to include everyone without missing the momentum that we were building.”
Regardless of the wider DEI forecast, the importance of firms creating inclusive workplaces with genuine champions for women remains.
“I don’t care what the climate is now,” said Ellison-Taylor. “These are people who are going to speak that truth no matter what the climate is because they know there are too many qualified women for them to only be on the stage with people who are just like them. And I love when they push back and they voice that. I love when they celebrate their women partners and they highlight them and they really give them an opportunity to really be out in front … . That’s when you show security and about your own self where you’re not threatened by the women in your firm because you’re giving them a chance and you want them to succeed.”
The Financial Accounting Standards Board met this week to discuss its projects on accounting for transfers of cryptocurrency assets and enhancing the disclosures around certain digital assets, such as stablecoins.
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During Wednesday’s meeting, FASB’s board made certain tentative decisions, according to a
At a future meeting, the board plans to consider clarifying the derecognition guidance for crypto transfer arrangements to assess whether the control of a crypto asset has been transferred.
FASB also began deliberations on the
The board decided to provide illustrative examples in Topic 230, Statement of Cash Flows, to clarify whether certain digital assets such as stablecoins can meet the definition of cash equivalents. It also decided to include the following concepts in the illustrative examples:
- Interpretive explanations that link to the current cash equivalents definition;
- The amount and composition of reserve assets; and,
- The nature of qualifying on-demand, contractual cash redemption rights directly with the issuer.
FASB plans to clarify that an entity should consider compliance with relevant laws and regulations when it’s creating a policy concerning which assets that satisfy the Master Glossary definition of the term “cash equivalents“ will be treated as cash equivalents.
“I agree with the staff suggestion to look at examples,” said FASB vice chair Hillary Salo. “From my perspective, I think that is going to help level the playing field. People have been making reasonable judgments. I agree with that. And I think that this is really going to help show those goalposts or guardrails of what types of stablecoins would be in the scope of cash equivalents, and which ones would not be in the scope of cash equivalents. I certainly appreciate that approach, and I think it has the least potential impact of unintended consequences, because I do agree with my fellow board members that we shouldn’t be changing the definition of cash equivalents, and it’s a high bar to get into the cash equivalent definition.”
“I’m definitely supportive of not changing the definition of cash equivalents,” said FASB chair Richard Jones. “I believe that’s settled GAAP in a way, and we’re not really seeing a call to change it for broader issues. I am supportive of the example-based approach. The challenge with examples, though, is everybody’s going to want their exact pattern, but that’s not what we’re doing.”
The examples will explain the rationale for how digital assets such as stablecoins do or do not qualify as cash equivalents and give a roadmap for other types of digital assets with varying fact patterns to be able to apply.
“We really don’t want to be as a board facing a situation where something was a cash equivalent and then no longer is at a later date,” said Jones. “That’s not good for anyone, so keeping it as a high bar with certain rigid criteria, I think, is fine.”
Stablecoins are supposed to be pegged to fiat currencies such as U.S. dollars and thus provide more stability to investors. “In my view, while a stablecoin may meet the accounting definition established for cash equivalents, not every one of those stablecoins in the cash equivalent classification represents the same level of risk,” said FASB member Joyce Joseph.
She noted that the capital markets recognize the distinctions and have established a Stablecoin Stability Assessment Framework to evaluate a stablecoin’s ability to maintain its peg to a fiat currency. Such assessments look at the legal and regulatory framework associated with the stablecoin, and provide investors with information that could enable them to do forward-looking assessments about the stability of the stablecoin.
“However, for an investor to consider and utilize such information for a company analysis the financial statement disclosures would need to include information about the stablecoin itself,” Joseph added. “In outreach, the staff learned that investors supported classifying certain stablecoins as cash equivalents when transparent information is available about the entities at which the reserve assets are held. Therefore, in my view, taking all of this into consideration a relevant and informative company disclosure would include providing investors with the name of the stablecoin and the amount of the stablecoin that is classified as a cash equivalent, so investors can independently assess the liquidity risks more meaningfully and more comprehensively by utilizing broader information that is available in the capital markets and its emerging information.”
Such information could include the issuer, reserves, governance and management, she noted, so investors would get a more holistic look at the risks that holding the stablecoin would entail for a given company.
The board decided to require all entities to disclose the significant classes and related amounts of cash equivalents on an annual basis for each period that a statement of financial position is presented.
Entities should apply the amendments related to the classification of certain digital assets as cash equivalents on a modified prospective basis as of the beginning of the annual reporting period in the year of adoption.
FASB decided that entities should apply the amendments related to the disclosure of the significant classes and amounts of cash equivalents on a prospective basis as of the date of the most recent statement of financial position presented in the period of adoption.
The board will allow early adoption in both interim and annual reporting periods in which financial statements have not been issued or made available for issuance.
FASB also decided to permit entities to adopt the amendments to be illustrated in the examples related to the classification of certain digital assets as cash equivalents without the need to perform a preferability assessment as described in Topic 250, Accounting Changes and Error Corrections.
The board directed the staff to draft a proposed accounting standards update to be voted on by written ballot. The proposed update will have a 90-day comment period.
Senators introduced several pieces of tax-related legislation this week, including measures aimed at improving customer service at the Internal Revenue Service, cracking down on tax evasion and curbing the carried interest tax break, in addition to efforts in the House to repeal the Corporate Transparency Act.
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Senators Bill Cassidy, R-Louisiana, and Mark Warner, D-Virginia, teamed up on introducing a bipartisan bill, the
The bill would establish a dashboard to inform taxpayers of backlogs and wait times; expand electronic access to information and refunds; expand callback technology and online accounts; and inform individuals facing economic hardship about collection alternatives.
“Taxpayers deserve a simple, stress-free experience when dealing with the IRS,” Cassidy said in a statement Wednesday. “This bill makes the process quicker and easier for taxpayers to get the information they need.”
He also mentioned the bill during a
“I’m happy to meet with the team … and do all I can to make it as good as you want it to be,” said Bisignano.
“My bill would equip the IRS with the legislative mandate to create an online dashboard so that taxpayers can monitor average call wait time and budget time accordingly,” said Cassidy. He noted that the bill would allow a callback for taxpayers that might need to wait longer than five minutes to speak to a representative, and establish a program to identify and support taxpayers struggling to make ends meet by providing information about alternative payment methods, such as installments, partial payments and offers in compromise.
“I know people are kind of desperate and don’t know where to turn for cash, so I think this could really ease anxiety,” he added. “This legislation is bipartisan and is likely to pass this Congress.”
Cassidy and Warner
“Taxpayers shouldn’t have to jump through hoops to get basic answers from the IRS — and in the last year, those challenges have only gotten worse,” Warner said in a statement. “I am glad to reintroduce this bipartisan legislation on Tax Day to ease some of this frustration by increasing clear communication and making IRS resources more readily available.”
Stop CHEATERS Act
Also on Tax Day, a group of Senate Democrats and an independent who usually caucuses with Democrats teamed up to introduce the Stop Corporations and High Earners from Avoiding Taxes and Enforce the Rules Strictly (Stop CHEATERS) Act.
Senate Finance Committee ranking member Ron Wyden, D-Oregon, joined with Senators Angus King, I-Maine, Elizabeth Warren, D-Massachusetts, Tim Kaine, D-Virginia, and Sheldon Whitehouse, D-Rhode Island. The bill would provide additional funding for the IRS to strengthen and expand tax collection services and systems and crack down on tax cheating by the wealthy.
“Wealthy tax cheats and scofflaw corporations are stealing billions and billions from the American people by refusing to pay what they legally owe, and far too many of them are getting a free pass because Republicans gutted the enforcement capacity of the IRS,” Wyden said in a statement. “A rich tax cheat who shelters mountains of cash among a web of shell companies and passthroughs is likelier to be struck by lightning than face an IRS audit, and Republicans want to keep it that way. This bill is about making sure the IRS has the resources it needs to go after wealthy tax cheats while improving customer service for the vast majority of American taxpayers who follow the law every year.”
Earlier this week. Wyden also
The Stop CHEATERS Act would provide the IRS with additional funding for tax enforcement focused upon high-income tax evasion, technology operations support, systems modernization, and taxpayer services like free tax-payer assistance.
“As Congress seeks ways to fund much-needed policy priorities and address our growing national debt, there is one common sense solution that should have unanimous bipartisan support: let’s enforce the tax laws already on the books,” said King in a statement. “Our legislation will make sure the IRS has the resources it needs to confront the gap between taxes owed and taxes paid – while ensuring that our tax enforcement professionals are focused on the high-income earners who account for the most tax evasion. This is a serious problem with an easy solution; let’s pass this legislation and make sure every American pays what they owe in taxes.”
Carried interest
Wyden, King and Whitehouse also teamed up on another bill Thursday to close the carried interest tax break for hedge fund managers that
Carried interest is a form of compensation received by a fund manager in exchange for investment management services, according to a
Under the bill, the
“Our tax code is rigged to favor ultra-wealthy investors who know how to game the system to dodge paying a fair share, and there is no better example of how it works in practice than the carried interest loophole,” Wyden said in a statement. “For several decades now we’ve had a tax system that rewards the accumulation of wealth by the rich while punishing middle-class wage earners, and the effect of that system has been the strangulation of prosperity and opportunity for everybody but the ultra-wealthy. There are a lot of problems to fix to restore fairness and common sense to our tax code, and closing the carried interest loophole is a great place to start.”
Repealing Corporate Transparency Act
The House Financial Services Committee is also planning to markup a bill next Tuesday that would fully repeal the Corporate Transparency Act, which has already been significantly
If enacted, the repeal would eliminate beneficial ownership reporting requirements, removing a transparency measure designed to help law enforcement and national security officials identify who is behind U.S. companies.
“This repeal would turn the United States back into one of the easiest places in the world to set up anonymous shell companies, something Congress worked for years to fix,” said Erica Hanichak, deputy director of the FACT Coalition, in a statement. “These entities are routinely used to facilitate corruption, financial crime, and abuse. Rolling back the CTA doesn’t just weaken transparency, it signals to bad actors around the world that the U.S. is once again open for illicit business.”
The Internal Revenue Service rarely penalizes taxpayers who have high balances in foreign bank accounts and fail to file the proper forms, according to a new report.
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The
Taxpayers with specified foreign financial assets that meet a certain dollar threshold are also required to report the information to the IRS by filing Form 8938. Failure to file the form can result in penalties of up to $60,000. However, TIGTA’s previous reports have demonstrated that the IRS rarely enforces these penalties.
The IRS created an Offshore Private Banking Campaign initiative to address tax noncompliance related to taxpayers’ failure to file Form 8938 and information reporting associated with offshore banking accounts, but it’s had limited success.
Even though the initiative identified hundreds of individual taxpayers with significant foreign bank account deposits who failed to file Forms 8938, the campaign only resulted in relatively few taxpayer examinations and a small number of nonfiling penalties. The campaign identified 405 taxpayers with significant foreign account balances who appeared to be noncompliant with their FATCA reporting requirements.
The IRS used two ways to address the 405 noncompliant taxpayers: referral for examinations and the issuance of letters to them.
- 164 taxpayers (who had an average unreported foreign account balance of $1.3 billion) were referred for possible examination, but only 12 of the 164 were examined, with five having $39.7 million in additional tax and $80,000 in penalties assessed.
- 241 noncompliant taxpayers (who had an average unreported account balance of $377 million) received a combination of 225 educational letters (requiring no response from the taxpayers) and 16 soft letters (requiring taxpayers to respond). None of the 241 taxpayers were assessed the initial $10,000 FATCA nonfiling penalty.
“While taxpayers can hold offshore banking accounts for a number of legitimate reasons, some taxpayers have also used them to hide income and evade taxes,” said the report.
Significant assets and income are factors considered by the IRS when assessing whether taxpayers intentionally evaded their tax responsibilities, the report noted. Given the large size of the average unreported foreign account balances, these taxpayers probably have higher levels of sophistication and an awareness of their obligation to comply with the law.
TIGTA believes the IRS needs to establish specific performance measures to determine the effectiveness of the FATCA program. “If the IRS does not plan to enforce the FATCA provisions even where obvious noncompliance is identified, it should at least quantify the enforcement impact of its efforts,” said the report. “This will ensure that IRS decision makers have the information they need to determine if the FATCA program is worth the investment and improves taxpayer compliance.
TIGTA made three recommendations in the report, including revising Campaign 896 processes to include assessing FATCA failure to file penalties; assessing the viability of using Form 1099 data to identify Form 8938 nonfilers; and implementing additional performance measures to give decision makers comprehensive information about the effectiveness of the FATCA program. The IRS disagreed with two of TIGTA’s recommendations and partially agreed with the remaining recommendation. IRS officials didn’t agree to assess penalties in Campaign 896 or with implementing performance measures to assess the effectiveness of the FATCA program.
“From our perspective, TIGTA’s conclusions regarding IRS Campaign 896 are based, in part, on a misguided premise and overgeneralizations, including the treatment of ‘potential noncompliance’ as tantamount to ‘egregious noncompliance’ that warrants a monetary penalty without contemplating the variety of justifications that may exempt a taxpayer from having to file Form 8938,” wrote Mabeline Baldwin, acting commissioner of the IRS’s Large Business and International Division, in response to the report.
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