IRS High-Wealth Examinations: IRS Wealth Squad, Targeted Issues, Preparation, IDRs, Appeals and Litigation

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

Thursday, November 5, 2020

1:00pm-2:50pm EST, 10:00am-11:50am PST

or call 1-800-926-7926

This webinar will review the IRS' latest campaign targeting upper-income taxpayers associated with flow-through entities and private foundations. Our audit experts will discuss the state of the current initiative and explain how to handle the IRS examination itself.


The IRS Large Business and International Division is auditing high net-worth individuals and their related entities, including partnerships, S corporations, trusts, and private foundations. The Wealth Squad, a relatively new, highly-trained, division of the IRS is conducting these audits.

These examinations will target recently enacted and complex areas of taxation, including:

  • Section 199A Qualified Business Income Deduction
  • Section 163(j) Business Interest Deduction Limitation
  • Section 965 Repatriation of Previously Untaxed Foreign Earnings
  • Section 172 Net Operating Loss Deduction Refund Claims
  • Required foreign reporting of trusts, bank accounts, assets, etc.

Although targeting specific areas, these are comprehensive audits covering most aspects of a taxpayers' tax return. Tax professionals working with high-wealth clients need to prepare for potential examinations and understand how to represent these taxpayers.

Listen as our panel of tax experts provides the latest information on these comprehensive audits, including the IRS selection process, information document requests (IDRs), supporting documentation, audit adjustments, appeals, and litigation.



  1. The current IRS initiative
  2. The structure of the IRS
  3. The selection process
  4. Proactive preparation
  5. The examination process
  6. Appeals
  7. Litigation


The panel will review these and other critical issues:

  • What is known about the current IRS selection process?
  • Which taxpayers and transactions are being targeted?
  • How can taxpayers best prepare for potential audits?
  • What caveats should tax professionals be wary of when representing taxpayers during high net worth audits?
  • When should a taxpayer go to appeals, and how does the current IRS appeals process work?


Stein, Michel
Michel R. Stein

Hochman Salkin Toscher Perez

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For...  |  Read More

Toscher, Steven
Steven (Steve) Toscher

Hochman Salkin Toscher Perez

Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions...  |  Read More

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