Research

Working Papers

1. Does Private Voluntary Disclosure Affect Audit Risk? with Andrew Belnap and Jeff Hoopes

Status: Submitted to JAR

Presentations: BYU Accounting Symposium 2025; JASO  monthly meeting Oct 2025; 118th NTA's Annual Conference on Taxation ;  38th Annual American Taxation Association Midyear Meeting; Norwegian School of Economics Workshop

The Deep Dive (AI  Generated) Podcast - How Voluntarily Disclosing Tax Secrets Via PLRs Cuts Audit Risk

Abstract: This paper examines the trade-off between voluntary private tax disclosure and audit risk associated with firms’ use of private letter rulings (PLRs). PLRs allow firms to seek binding guidance from the Internal Revenue Service (IRS) on the tax treatment of specific transactions, reducing uncertainty but requiring voluntary disclosure of sensitive tax information to the IRS. Using a novel dataset of PLRs disclosed in public firms’ SEC filings, we find that firms receiving a PLR for the first time experience a decreased likelihood of audit. These results are concentrated in small firms, and those with moderate levels of tax avoidance. We find no other change in tax outcomes—GAAP ETRs, Cash ETRs, or UTBs, suggesting that firms’ tax behavior does not change following receipt of the PLR. We find firms that disclose PLRs also change tax disclosure, suggesting they perceive and want to convey to stakeholders this decreased audit risk. Our study contributes to the literature on corporate tax strategy, voluntary disclosure, and tax enforcement by providing large-sample empirical evidence on the effects of PLRs. For policymakers, our results suggest that expanding the availability of PLRs or similar programs could improve tax compliance and reduce enforcement costs for both firms and the IRS 

2. The Chilling Effect of ICE: Confidentiality Concerns and Taxpayer Assistance Take-up with Hannah Judd and Daphne Armstrong

Status: Working Paper

Presentations: BYU Accounting Symposium 2026

Abstract: We examine whether an erosion of taxpayer confidentiality affects taxpayer assistance take-up. Taxpayer privacy has long been a hallmark of the U.S. tax system, but that protection was substantially undermined in April 2025 when the Internal Revenue Service (IRS) entered into an information-sharing agreement with Immigration and Customs Enforcement (ICE). Using weekly data on visits to IRS Taxpayer Assistance Centers, we document a decline in the share of assistance involving potentially immigration-sensitive taxpayer information at centers located in communities more exposed to immigration-related confidentiality concerns. We do not find significant changes in overall assistance visits, suggesting that the effect is concentrated among services involving information that may be particularly sensitive if shared with immigration-enforcement agencies. The findings are consistent with a targeted chilling effect on taxpayer assistance involving potentially immigration-sensitive information and suggest that concerns about the non-tax use of taxpayer information can influence engagement with the IRS.

3. Can Taxpayers and Tax Authorities Be Friends: Evidence on Spillover Tax Enforcement Efficiency from Cooperative Tax Compliance 

Status: Working paper / 2026 JSRP IRS Data Proposal

Presentations: UT Austin Workshop; BYU Accounting Symposium 2026

Abstract: Cooperative compliance programs are meant to streamline tax enforcement efficiency by replacing delayed, adversarial audits with contemporaneous, cooperative reviews. These efficiencies spill over to non-participating peers when participation generates reusable knowledge (knowledge sharing) or unlocks resources (resource reallocation). However, the efficiency of cooperative compliance programs is uncertain due to difficulties with implementing cooperative engagements. I use a novel dataset of U.S. Compliance Assurance Process (CAP) participation to test whether and how cooperative compliance programs improve tax authority enforcement efficiency amongst peer firms. Consistent with improved efficiency, I find that after the entrant of a new CAP participant, non-CAP peers more exposed to local knowledge sharing experience 25% shorter audit cycles, with no decline in capacity allocated, audit coverage, or audit yield. These results are directionally similar but much weaker amongst national knowledge sharing. Resource reallocation tests suggest that the IRS redirects excess capacity generated by CAP to audit more difficult positions. Using the Tax Cuts and Jobs Act (TCJA) as an alternative shock, I further find that audit cycles increase by 1.5 years for firms exposed to complex new tax legislation, but that proximity to CAP participants more than reverses this effect, consistent with CAP-generated knowledge helping the IRS respond more efficiently to new tax complexity. My findings suggest that cooperative compliance programs improve enforcement efficiency for tax authorities and that policymakers should consider spillovers when designing, implementing, and evaluating cooperative compliance programs.