Global High Wealth Industry Audits Underway—Observations from the Foxhole

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It’s a sure sign of a tough audit when the Commissioner of Internal Revenue sets a tough tone for his agents: “Many high wealth individuals make use of sophisticated financial, business, and investment arrangements with complicated legal structures and tax consequences. Many of these arrangements are above board. Others mask aggressive tax strategies.” Commissioner Shulman, Prepared Remarks before the 22nd Annual George Washington University International Tax Conference, December 10, 2009. And, of course, why would something need to be “masked” if it wasn’t suspect? The Commissioner has also described these arrangements as a “complex web of business entities.” Commissioner Shulman, Prepared Remarks to the New York State Bar Association Taxation Section Annual Meeting in New York City, January 26, 2010. This is not exactly neutral terminology; recall Sir Walter Scott’s famous line “oh what a tangled web we weave,” you know the rest. The Commissioner has essentially declared audit war on what are likely to be in many instances legitimate tax savings structures.

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