Extra, Extra: IRS Division of Tax Exempt and Government Entities Releases FY2023 Program Letter

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Cory D. Halliburton

Cory D. Halliburton



Cory Halliburton serves as general counsel and business adviser to a nationwide nonprofit / tax-exempt client base, as well as for multi-state professional service companies. He is a results-oriented attorney, with executive-level strategy and an understanding of the intersection of law and business judgment. With a practical upbringing, he pushes for process-driven results in internal governance, strategy and compliance with employment law, and complex or unique contracts and business relationships.

He dedicated the first ten years of his practice to mainly commercial litigation matters in West Texas and the Dallas-Fort Worth Metroplex. During that experience, Mr. Halliburton transitioned his practice to a more general counsel role, with an emphasis on nonprofit and tax-exempt organizations, advising those organizations through formation, dissolution, litigation, governance, leadership succession, employment law, contracts, intellectual property, tax exemption issues, policy creation, mergers and other. He has served as borrower’s counsel for tax-exempt bond and loan transactions near $100 million aggregate; some with complex pre-issue construction, debt payoff and other debt financing challenges.

Mr. Halliburton also serves as outside legal and business advisor for executive professionals in multi-state engineering firms, with a focus on drafting and counsel on significant service agreements, employment law matters, and protection of trade secrets.

On November 4, 2022, the Tax Exempt and Government Entities division of the IRS (TE/GE) released its Fiscal Year 2023 Program Letter (2023 Program).

The 2023 Program is intended to dovetail with the IRS Strategic Plan FY2022-2026. Under that Strategic Plan, the IRS’s Mission is: “Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.” The Plan includes key performance indicators in areas of Service, Enforcement, Transformation, and People. For Enforcement, the IRS’s objectives are to:

A key pillar of the 2023 Program is to “Strengthen Compliance Activities (Enforcement)”. TE/GE will focus on collaboration with IRS divisions of Criminal Investigations; Large Business & International; Small Business/Self-Employed; and Research, Applied Analytics & Statistics. A TE/GE priority includes selecting and examining returns for compliance action. TE/GE’s collaboration is aimed at creating a unified compliance plan to enable effective tax administration.

As for People, the 2023 Program indicates that TE/GE hired 187 new employees in FY2022, and TE/GE anticipates a greater number in FY2023. In the Service arena, TE/GE expects to continue with appropriate compliance workstreams – education letters, compliance checks, or exams – in order to balance TE/GE and taxpayer burdens for effective enforcement of tax laws.

As calendar year 2022 enters its end-of-life phase, the TE/GE Fiscal Year 2023 Program Letter gives tax practitioners of an idea of what we might see in the near future and into 2023, at least from a tax-exempt and governmental entities perspective.