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. […]
Category: Audits
On October 1, 2025, the Internal Revenue Service (IRS) announced the launch of a two-year pilot program that is designed “to make Post Appeals Mediation (PAM) more attractive to taxpayers.” Post-Appeals Mediation is one of a handful of options available to individual and corporate taxpayers who disagree with the IRS’ […]
The Internal Revenue Service (IRS) offers a variety of options to large business and international taxpayers that need to resolve tax controversies at the pre-filing or pre-audit stage. These options are specifically tailored to taxpayers that fall under the jurisdiction of the IRS’s Large Business and International (LB&I) Division, which […]
With Tax Day just around the corner, now is a time of year when many people, particularly high-income and high-net-worth taxpayers, begin to have concerns about the possibility of facing an IRS audit. Even if you do your best to meet your federal tax obligations—and even if you rely on […]
Internal Revenue Service (IRS) audits can present substantial risks, especially for high-income and high-net-worth taxpayers. Not only can revenue agents impose liability for back taxes, interest, and penalties, but if they uncover apparent evidence of an intentional unlawful tax avoidance scheme, they can engage Special Agents from IRS Criminal Investigation […]
While partnerships have long been on the Internal Revenue Service’s (IRS) enforcement radar, it has lacked the funding needed to target partnerships at scale and effectively audit large partnerships with billions of dollars in assets and annual revenue. But, this changed with the enactment of the Inflation Reduction Act in […]
While facing a federal tax audit can be risky in any circumstance, it can be especially risky if you have concerns about tax code compliance. For high-income and high-net-worth taxpayers, non-compliance with the Internal Revenue Code can create substantial exposure—including exposure to liability for interest and penalties. With this in […]
If you are like most high-income and high-net-worth taxpayers, you rely on professionals to help make sure you pay what you owe (while also making sure you pay as little as possible). So, what happens if one of your tax professionals makes a mistake? Are you liable to the Internal […]
If you received an unfavorable audit determination from the Internal Revenue Service (IRS), challenging the outcome of your audit will involve filing an appeal. In most cases, this starts with filing a “protest” with the appropriate IRS office. Before you file, however, you need to ensure that doing so is […]
The Internal Revenue Service (IRS) routinely targets high-income and high-net-worth taxpayers suspected of using abusive tax shelters to evade federal tax liability. Abusive tax shelters fall into several categories, the broadest of which are the IRS’ “Listed Transactions.” As federal tax audits and investigations targeting Listed transactions can present substantial […]