News & Analysis as of

Tax Liability High Net-Worth Tax Planning

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

Mayer Brown on

In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...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

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

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

The States Come Marching In: Investors Ignore State Wealth Taxes at Their Peril

As President Biden reminded taxpayers in his recent State of the Union address, the federal government continues to pursue new taxes on high-net-worth individuals. While such efforts have foundered in Congress, causing many...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

Allen Matkins

Attention Property Owners: Los Angeles and Santa Monica Approve ‘Mansion Tax’ Ballot Measures, Increasing Transfer Taxes on Sales...

Allen Matkins on

Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more

Polsinelli

The Proposed Build Back Better Act Moves Forward After the House Passes a Revised Version of the Bill

Polsinelli on

Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Billionaires Tax

On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Foodman CPAs & Advisors

The Tax Gap To Rise To Approximately $7 Trillion

The US Treasury reports that it is expecting the tax gap to rise to approximately $7 trillion over the course of the next decade if left unaddressed.   In May 2021, the US Department of the Treasury issued the “THE AMERICAN...more

Foodman CPAs & Advisors

High-Income Individuals And Corporate Tax Returns Are Targets Of IRS Additional Funding Program

The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net  Worth Individuals...more

Holland & Knight LLP

Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce

Holland & Knight LLP on

Divorce is not a topic most clients or tax advisors enjoy discussing. Nevertheless, it is important in today's day and age to advise clients, especially high-net-worth individuals with substantial assets located in the U.S....more

Cadwalader, Wickersham & Taft LLP

Democrats Propose Mark-to-Market Tax and Increased Audits on High-Net-Worth Individuals

Democrats at both the federal and state levels are proposing a “mark-to-market” tax and legislation that would mandate more audits on high-income taxpayers....more

Foodman CPAs & Advisors

Comisionado del IRS envía un Mensaje Importante a los Contribuyentes de Altos Ingresos que No Declaran

El 3 de diciembre del 2020, el IRS publicó “Cómo el IRS prioriza el trabajo de cumplimiento en los no declarantes de altos ingresos a través de esfuerzos nacionales e internacionales” en el Estudio titulado “Closer Look”.  El...more

Foodman CPAs & Advisors

IRS Commissioner Hylton sends an important message to high income non-filers

Foodman CPAs & Advisors on

On December 3, 2020, the IRS published  “How the IRS prioritizes compliance work on high income non-filers through national and international efforts” in the Closer Look.  ...more

Foodman CPAs & Advisors

Audit Time for High Income Individuals and their Companies has arrived

On a webinar hosted by the New York University Tax Controversy Forum on June 18, 2020, Douglas O’Donnell (head of the IRS Large Business and International Division/IRS-LBI) stated that the IRS will  begin a new campaign to...more

Jones Day

IRS to Begin Examination of Hundreds of High-Wealth Individuals Starting July 15

Jones Day on

The Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private...more

Morgan Lewis

Athletes, Artists, and Audits: IRS Renews Focus on High-Wealth Individuals and Associated Entities

Morgan Lewis on

The IRS has announced its intention to audit wealthy taxpayers and their associated business entities starting in mid-July. This LawFlash alerts sports owners, athletes, entertainers, and others in these industries to the...more

McDermott Will & Emery

[Event] 2019 Private Client East Coast Forum - November 21st, New York, NY

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The unique needs of ultra-high net worth families, their family office representatives and other advisers are multidimensional and ever-evolving. Join us November 21 for McDermott Will & Emery’s Private Client East Coast...more

McDermott Will & Emery

[Event] 2019 Private Client West Coast Forum – November 8th, Palo Alto, CA

McDermott Will & Emery on

Please join us this November for McDermott Will & Emery’s Private Client West Coast Forum. At this complimentary program, experienced McDermott partners will lead discussions on a broad range of topics pertinent to ultra-high...more

McDermott Will & Emery

[Event] 2019 Private Client West Coast Forum – November 7th, San Francisco, CA

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Please join us this November for McDermott Will & Emery’s Private Client West Coast Forum. At this complimentary program, experienced McDermott partners will lead discussions on a broad range of topics pertinent to ultra-high...more

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