The aggressive compliance landscape started several years ago and slowed down due to Covid-19. However, in recent months tax practitioners are seeing an increase in compliance efforts and controversies throughout the world. It started in January 2017 when the IRS began a new approach to examination where they were targeting campaign issues that they think have potential for noncompliance. For example, the IRS began to target Code Section 965 which affects a lot of taxpayers. They also have the high-wealth initiative, which targets very wealthy individuals not only around the US, but around the world.