MICHEL R. STEIN to Speak at Upcoming Florida Tax Institute
We are pleased to announce that Michel R. Stein will be speaking at the upcoming 11th Annual Florida Tax Institute 3-Day Conference on the on the topic of “Audits and Tax Controversy Update” on Wednesday, February 14, 2024, 2:15 p.m. – 3:15 p.m. (EST), along with co-panelists Fred Murray (IRS Special Counsel), Eric Cerelli (IRS Field Director for Global High Wealth), Judy McNamara (IRS Field Director for International Individual Compliance) and Niles Elber (Caplin & Drysdale).
The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions, as well as collection of outstanding tax liabilities of these taxpayers. The reviews are expected to include the individual tax return of the sophisticated taxpayer as well as related partnerships, foundations, trusts, retirement plans, and other business structures. The IRS also has reaffirmed its interest in cross-border activities with the announcement of new campaigns targeting Nonresident Aliens who receive rental income from U.S. real property; FIRPTA compliance in connection with the withholding of tax and reporting obligations on the disposition of U.S. real property interests; and the U.S. activities of financial service entities and whether foreign investors participating in “inbound” lending transactions were engaged in a U.S. trade or business and generated income effectively connected with a U.S.-situs lending trade or business. Examination of partnerships and other flow-through entities are in themselves a focus of a number of examinations. The panel will discuss current developments and their implications for high wealth foreign and domestic taxpayers.