News & Analysis as of

High Net-Worth Income Taxes

Holland & Knight LLP

Maximize Your Legacy: Take Advantage of the High Estate and Gift Tax Exemption Sunset

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As part of the Tax Cuts and Jobs Act (TCJA), the estate and gift tax exemption was doubled for tax years 2018-2025. In 2018, the exemption doubled from $5.49 million in 2017 to $11.18 million in 2018, and that amount has been...more

Foodman CPAs & Advisors

High Income High Wealth Taxpayers Pursued By IRS

On 5/4/24, the U.S. Department of the Treasury and the IRS outlined the accomplishments achieved in the first year of implementation of the Strategic Operating Plan, a comprehensive roadmap to transform the IRS using...more

Foodman CPAs & Advisors

Individuos De Alto Patrimonio Reciben Advertencia Del IRS

El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more

Foodman CPAs & Advisors

High Net Worth Individuals Get Warning From IRS

On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more

Nutter McClennen & Fish LLP

Legacy Matters (Fall 2023)

Welcome to the first edition of Legacy Matters, Nutter’s private wealth and nonprofit newsletter focusing on estate planning and philanthropy topics. ...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

McDermott Will & Emery

IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

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On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more

Gray Reed

The IRS is Hiring an Army to Audit Corporations, Partnerships, and High-Income Individuals

Gray Reed on

The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted.  The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more

Greenberg Glusker LLP

Top Tax and Legal Considerations for Wealthy Families Going Global

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In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Gray Reed

Is Your Partnership Ready for IRS Audit Initiatives? Because the IRS is Coming!

Gray Reed on

On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will establish a special...more

Woods Rogers

IRS Announces New Initiatives to Restore Fairness to Tax System

Woods Rogers on

On September 8, 2023, the IRS announced the start of a “sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promotors...more

Polsinelli

IRS Says: New Goal is to Restore Fairness by Using Tax Dollars to Audit More Millionaires, Partnerships and Large Corporations

Polsinelli on

Following our initial reaction to the Internal Revenue Service's strategic operating plan to spend $80B in funding allocated from the Inflation Reduction Act, Polsinelli’s Tax attorneys continue to monitor the IRS’ compliance...more

Allen Barron, Inc.

IRS Warns High Income US Taxpayers and Millionaire Non-Filers

Allen Barron, Inc. on

The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

Polsinelli on

After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Cadwalader, Wickersham & Taft LLP

Potential Constitutional Challenge: Biden Budget Proposes Mark-to-Market for High-Net-Worth Individuals

In President Biden’s State of the Union address, he called on all Americans to pay their “fair share.” The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals contains several...more

Brownstein Hyatt Farber Schreck

White House Releases FY 2024 Budget Request

Earlier today, the White House released its fiscal year (FY) 2024 budget request to Congress. Overall, it proposes $6.9 trillion in total spending, including a proposed $880 billion for defense and approximately $992 billion...more

Foley Hoag LLP - White Collar Law &...

2023 Trends in Criminal Tax Enforcement

This is the second part in our 2023 series examining important trends in white collar law and investigations. Up next: crypto enforcement. The days of decreased IRS enforcement activity may be coming to a close. Although...more

Rivkin Radler LLP

Will New York Increase Taxes On Investment Income?

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Last Thursday, New York State Senator Gustavo Rivera, who represents the 33rd District (basically, the northwestern quadrant of The Bronx), proposed legislation that seeks to collect more taxes from the State’s high-income...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

Morgan Lewis on

The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Goulston & Storrs PC

Taxachusetts Redux? The New Massachusetts Millionaires Tax

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On November 8, 2022, Massachusetts voters elected to adopt Question 1, the so-called Fair Share Amendment or Massachusetts Millionaires Tax, through a ballot referendum. The referendum amends the Massachusetts state...more

Polsinelli

New York Alleges Trump Procured Inflated Appraisals for Conservation Easements

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On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more

Gerald Nowotny - Law Office of Gerald R....

All in the Family – Introducing Family Owned Life Insurance™ (aka FOLI™)

The All in the Family podcast introduces Family Owned Life Insurance™ or (FOLI™). FOLI™ is a specialty use of group private placement life insurance for Family Offices. FOLI™ is a powerful product that will allow Family...more

Cadwalader, Wickersham & Taft LLP

A Pocket Guide to the 2023 Budget Proposals

On March 28, 2022, the Biden Administration released its budget proposal for Fiscal Year 2023 (the Budget). We summarize below the tax aspects of the Budget of particular interests to U.S. corporate taxpayers, financial...more

Proskauer - Tax Talks

The Biden Administration Proposes Mark-to-Market Minimum Tax on Individuals With More than $100 Million in Assets

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Summary and Background. On March 28, 2022, the Biden Administration proposed a 20% minimum tax on individuals who have more than $100 million in assets.  The minimum tax would be based on all economic income (which the...more

Jones & Keller, P.C.

Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller

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High-net worth individuals have an opportunity to take advantage of high transfer tax exemptions if they act fast. Set to expire in 2026, unless Congress acts sooner, the time is now to implement strategies that make the most...more

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