High Net Worth Taxpayers and The IRS Wealth Squad

Our tax controversy lawyers have represented numerous high net worth individuals and their closely held entities involved in examinations conducted by the Global High Wealth Industry Group of the IRS Large Business and International division (commonly referred to as the IRS “Wealth Squad”). This is a specialized, experienced group of IRS examiners solely focused on conducting audits of high-income/high-wealth taxpayers and their related closely held entities.

In a typical Wealth Squad examination, the IRS deploys a team of highly capable, experienced examination specialists which include technical advisers to provide industry or issue specialized tax expertise, flow-through entity specialists, international examiners, economists to identify economic trends within returns, valuation experts issues and others. Related entities examined often include partnerships, trusts, S corporations, C corporations, private foundations, etc. The examination often includes other individual income tax returns affected by flow-through adjustments made on the tax returns for related partnerships and S corporations, thus impacting other investors in the same entity. Given the complex nature of such examinations, we are often engaged to assist in the coordination of information for high net worth individuals and their entities long before they receive any notice of examination. Preparation, including advance preparation, is often a significant factor in achieving a favorable and efficient resolution of a Wealth Squad examination.

Our tax controversy lawyers typically work closely with the family office and other professionals associated with the high net worth individual. During these examinations, we coordinate and analyze relevant information and documentation, appropriately respond to IRS inquiries, and fully engage the Wealth Squad examination team throughout the entire process. When necessary, our tax litigators are prepared to litigate any unresolved issues.

If you may be subjected to a Wealth Squad examination, we can help.