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Concurrent Session Onsite and Online

SOP2104. Enforcement Priorities: High-Income Non-Filers & High Wealth Taxpayers

Since March 2020, the IRS has elevated fraud enforcement to new heights with the establishment of the Office of Fraud Enforcement, led by a former IRS Criminal Investigation Special Agent in Charge and Director of International Operations; appointment of National Fraud Counsel; and creation of the Office of Promoter Investigations, led by a veteran of the IRS with extensive experience managing investigations and examinations involving abusive transactions. The IRS also has enhanced fraud training efforts across the IRS operating divisions, reinforced fraud referral procedures with subject matter experts, announced new compliance campaigns, and initiated parallel proceedings targeting taxpayers and professional enablers participating in abusive tax avoidance schemes. Priority areas include, but are not limited to, high income non-filers, micro-captive insurance, syndicated conservation easements, virtual currency, the gig economy, and Puerto Rico residency programs. This session will discuss the current state of enforcement against high income/high wealth taxpayers and what we can expect in the days to come.

Learning Objectives:

  • Understand the IRS focus on fraud enforcement
  • Understand the IRS current enforcement priorities
CPE Credits
NASBA Field of Study
3-5 Years in the Profession
Advanced Preparation
Session Tags
Sophisticated Tax