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IRS' Current Audit Campaign: Preparing for Large Partnership, Complex PTE, and HNW Taxpayer Examinations

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, February 27, 2024

Recorded event now available

or call 1-800-926-7926

This webinar will discuss the IRS' latest audit efforts, focusing on pass-through entities (PTEs) and high income taxpayers. Our panel of astute tax attorneys will explain the IRS' use of artificial intelligence (AI) to assist with these examinations, key PTE issues and entities it is examining, and steps individuals and PTEs can take to prepare for these imminent audits.


In Notice 2023-166, the IRS announced its shift in focus from working-class taxpayers to wealthy taxpayers. With funds supplied by the Inflation Reduction Act, the IRS is concentrating its attention on large corporations and partnerships, high-income earners, and abusive tax avoidance promoters.

Within the notice, the IRS explained that a "major expansion in high-income/high wealth and partnership compliance work" is a key element of the new campaign. Specifically included are taxpayers with income above $1 million and more than $250,000 in tax debt, and partnerships with over $10 million in assets with ongoing balance sheet discrepancies. Perhaps the greatest cause of unrest is the IRS' statement that its compliance team will use AI to aid in these examinations.

The IRS established a new division within its Large Business and International Division to assist with these audits. This new IRS unit will take a broader look at all complex partnerships. With the heightened reporting requirements for these flow-through entities, PTE practitioners and owners need to be wary but ready for the IRS' latest campaign.

Listen as our panel of notable federal tax litigation experts analyzes the IRS' current enforcement efforts and steps partnerships and high net worth individuals must take to prepare.



  1. IRS’ latest campaign: an introduction
  2. Large partnership audits
  3. Other partnership audits
  4. High wealth taxpayers
  5. IRS' use of AI in audits
  6. Initial audit considerations and responses
  7. Other examination considerations


The panel will review these and other critical issues:

  • What specific partnership issues is the IRS examining?
  • What immediate actions should a partnership take when an examination notice is received?
  • How is the IRS using AI to assist with its audits?
  • What businesses and individuals are targeted by the IRS in this most recent campaign?


Horwitz, Robert
Robert Horwitz

Hochman Salkin Toscher Perez

Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil...  |  Read More

Kalinski, Jonathan
Jonathan Kalinski

Hochman Salkin Toscher Perez

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including...  |  Read More

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