2025 Year in Review: Key Insights for High-Income and High-Net-Worth Taxpayers
In 2025, we published dozens of articles on our blog that provide important insights and practical information for high-income and high-net-worth taxpayers. The Internal Revenue Service (IRS) places particular emphasis on targeting high-income and high-net-worth taxpayers suspected of noncompliance, and facing IRS scrutiny can expose these taxpayers to substantial liability. Here, Texas tax attorney Lawrence Brown takes a look back at some of the key insights we shared throughout the year.
Facing an IRS Audit: Understanding the Basics
IRS audits can target all forms of noncompliance with the Internal Revenue Code, as well as noncompliance with the Bank Secrecy Act, Foreign Account Tax Compliance Act (FATCA), and various other federal statutes. When facing an IRS audit, it is critical to know what you can expect, and it is equally important to know what you need to do in order to minimize your risk. Learn more:
IRS: Falling Victim is Not an Excuse for Noncompliance
Tax scams proliferated online in 2025, including scams targeting high-income and high-net-worth taxpayers. While the IRS acknowledges that falling for these scams is a very real risk, it also makes clear that falling victim is not an excuse for noncompliance. As a result, for taxpayers who have fallen victim to online scams, taking a wait-and-see approach with the IRS is not an option. Learn more: IRS Warns of Tax Scams, Reminds Taxpayers That They Are Responsible for Their Returns.
Pre-Filing and Post-Filing Options for Resolving High-Stakes Federal Tax Controversies
In the middle of the year, we published a series of articles examining the IRS’s pre-filing and post-filing resolution options. While there are several options available, each of these options is particularly well-suited to a particular set of facts and circumstances. As a result, for taxpayers who need to attempt to proactively resolve high-stakes federal tax controversies with the IRS, making an informed decision is critical. Learn more:
Pandemic-Era Fraud Remains a Top IRS Enforcement Priority
As we head into 2026, targeting pandemic-era fraud remains a top enforcement priority for the IRS and IRS Criminal Investigation (IRS CI). This includes fraud under the Paycheck Protection Program (PPP) and Employee Retention Credit (ERC) programs. The IRS has identified billions of dollars in alleged fraud under each of these programs, and it is pursuing both civil tax audits and criminal investigations to hold businesses and their owners accountable. Learn more:
Failure to Pay Estimated Tax Can Also Present Substantial Risks for High-Income Taxpayers
Along with pandemic-era fraud, the IRS has recently been prioritizing enforcement of taxpayers’ mid-year tax filing obligations as well. This includes taxpayers’ obligations to make quarterly estimated tax payments when they don’t have traditional withholdings. When taxpayers fail to make estimated tax payments, interest and penalties begin to accrue immediately. Learn more: Failure to Pay Estimated Tax: What U.S. Taxpayers Need to Know.
What High-Income and High-Net-Worth Taxpayers Need to Know When Facing IRS Collection
Whether due to allegations of pandemic-era program fraud, failure to pay estimated taxes, or any other violation of federal law, high-income and high-net-worth taxpayers facing IRS collection need to act immediately. While there are options available, some may be off the table once the IRS seizes your assets or initiates other collection methods. Learn more:
IRS CI Investigations Can Target Both Tax-Related and Non-Tax-Related Crimes
While IRS CI investigates taxpayers suspected of all forms of tax evasion and fraud, it also investigates those suspected of non-tax-related crimes. These include accounting fraud, embezzlement, money laundering, and others. With this in mind, when facing scrutiny from IRS CI, it is imperative that high-income and high-net-worth taxpayers have a comprehensive understanding of all charges on the table. Learn more:
The IRS is Targeting Tax Preparers, Too
In addition to targeting high-income and high-net-worth taxpayers, the IRS also targets their tax preparers in many cases. Tax preparers can face scrutiny for a wide range of alleged civil and criminal offenses, from facilitating tax fraud to taking advantage of their well-heeled clients. Learn more:
Rectifying Tax Mistakes Before They Trigger a Civil Tax Audit or Criminal Investigation
For taxpayers (and tax preparers) who have made mistakes, taking a proactive approach to working with the IRS will be advantageous in most scenarios. But what this entails depends on the specific circumstances involved. For example, while taxpayers can submit amended returns and streamlined filings in some cases, in others, they may need to consider submitting a voluntary disclosure to the IRS CI. Learn more:
Request a Call with Texas Tax Attorney Lawrence Brown
If you have questions or concerns about your federal tax obligations as a high-income or high-net-worth taxpayer heading into 2026, please contact us. To request a call with Texas tax attorney Lawrence Brown, please call 888-870-0025 or contact us confidentially online today.