TAX2519. Examination of Wealthy HNW/UHNW Individuals and Their Family Offices

The IRS has billions of dollars in supplemental long-term funding to modernize and implement an array of new and expanded enforcement programs significantly focused on high-net-worth (HNW) and ultra-high-net-worth (UHNW) individuals and their related entities. In this regard, the IRS has made considerable effort in using advanced data and analytics to identify non-compliant taxpayers and has moved forward to building specialized examination teams. Be prepared—effective representation techniques and strategies when representing HNW/UNHW individuals and their family offices will be discussed by the former IRS commissioner and the former counselor to the IRS commissioner.

Learning Objectives:

• Recognize the current IRS Global High Wealth Program and Large Business & International (LB&I) Division or Small Business/Self-Employed (SBSE) High Income Initiative enforcement priorities.
• Recognize representation of high-net-worth (HNW) and ultra-high-net-worth (UHNW) individuals and their related entities during an IRS examination or administrative appeal.
• Distinguish between the significance of an IRS Global High Wealth Program specialized examination versus an LB&I or SBSE High Income Initiative examination.
• Identify effective dispute resolution techniques and strategies.