News & Analysis as of

High Net-Worth Internal Revenue Service

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Lippes Mathias LLP

Know Your Rights: Managing Exposure During Audits Through Legal Representation

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The 2022 Inflation Reduction Act (the “IRA”) allocated $80 billion in funding to the Internal Revenue Service (“IRS”), much of which was earmarked for increased enforcement efforts. After some starts and stops, that funding...more

Hinshaw & Culbertson LLP

Use It or Lose It: Federal Gift and Estate Tax Exemption Set to Sunset at the End of 2025

The Tax Cuts and Jobs Act (TCJA) of 2017 nearly doubled the federal lifetime gift and estate tax exemption. In 2024, this act currently allows individuals to transfer up to $13.61 million per person and $27.22 million per...more

McDermott Will & Emery

Weekly IRS Roundup July 8 – July 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8, 2024 – July 12, 2024. ...more

Holland & Knight LLP

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

Holland & Knight LLP on

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

Contribuyentes De Altos Ingresos Y Patrimonios Perseguidos Por El IRS

El 5/4/24, el Departamento del Tesoro de EE. UU. y el IRS describieron los logros alcanzados en el primer año de implementación del Plan Operativo Estratégico, una hoja de ruta integral para transformar el IRS utilizando los...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

Husch Blackwell LLP

Understanding the 2026 Changes to the Estate, Gift, and Generation-Skipping Tax Exemptions

Husch Blackwell LLP on

The Tax Cuts and Jobs Act of 2017 provided major changes to the Internal Revenue Code, specifically doubling the federal estate, gift, and generation-skipping transfer (GST) tax exemption (collectively, the exemption) from...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 (Spring 2024)

Welcome to the spring edition of Legacy Matters, Nutter’s private wealth and nonprofit newsletter focusing on estate planning and philanthropy topics. In this issue, we analyze charitable deductions and required recordkeeping...more

Allen Barron, Inc.

New Corporate Tax Increase Proposal and Focused IRS Audits - Is the Cost of Business Going Up?

Allen Barron, Inc. on

The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more

Falcon Rappaport & Berkman LLP

IRS Announces Audits of Business Jet Usage as Part of Larger Effort to Target High-Income Taxpayers

On February 21, 2024, the IRS announced plans to begin audits on aircraft that may be used for both business and personal purposes. This push is a part of the IRS’s broader focus on improving tax compliance in high-income...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

McDermott Will & Emery on

McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Foodman CPAs & Advisors

Inteligencia Artificial Asiste Al IRS Con Los Evasores De Impuestos

El 20/09/23, el IRS anunció que planea establecer un área especial para centrarse en entidades de transferencia grandes o complejas para ayudar con los esfuerzos de cumplimiento de altos ingresos. Con la ayuda de tecnología...more

Foodman CPAs & Advisors

IRS Y Sus Nuevos Esfuerzos De Cumplimiento

Foodman CPAs & Advisors on

En 9/8/23, el IRS anunció nuevos esfuerzos de cumplimiento que se centrarán en aumentar el escrutinio de los contribuyentes de altos ingresos/altos patrimonios, sociedades, corporaciones y promotores que abusan de las normas...more

Foodman CPAs & Advisors

New IRS Compliance Efforts

On 9/823, the IRS announced new compliance efforts that will focus on increasing scrutiny on high-income taxpayers, partnerships, corporations and promoters abusing tax rules on the books by using Artificial Intelligence and...more

Allen Barron, Inc.

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

Allen Barron, Inc. on

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

McDermott Will & Emery on

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

Fox Rothschild LLP

IRS Going All in on Use of ArtificiaI Intelligence

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The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows...more

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