HIDE

Other Publications

Insights

Publications

Examining High Net Worth Taxpayers in the U.S.

Volume 11 No 6    /    Read Article

By Philip Colasanto (Guest Author)

Beginning in 2023, I.R.S. D.O.J. took up the call with programs of enhanced (i) I.R.S. examinations of high-net-worth individuals, large partnerships, and large corporations and (ii) D.O.J. prosecutions of persons accused of criminal tax offenses. The first initiative focused on taxpayers with income of more than $1 million and tax debt in excess of $250,000. The second initiative expanded the focus to large partnerships, which traditionally have more than $10 million in assets. Included were hedge funds, real estate investment partnerships, publicly traded partnerships, and large law firms. At the same time, D.O.J. began prosecuting a slew of recalcitrant taxpayers with significant means, whose tax schemes resulted in millions of dollars in lost tax revenue. Philip Colasanto, a senior associate in the New York Office of Withers Bergman L.L.P. (WithersWorldwide) takes a deep dive into the initiatives and the prosecutions. He goes on to explain various ways that are available to taxpayers wishing to come into compliance regarding past reporting failures.   See more →