On March 11, 2021, Caroline D. Ciraolo participates in a panel entitled “Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures” at the Florida Tax Institute’s 2021 Conference.

Description: The IRS has again increased its focus on examinations of high-wealth individuals. Each review is expected to include the individual tax return of the sophisticated taxpayer as well as related returns such as partnerships, foundations, trusts, and other business entities. Similarly, the IRS has recently announced a number of other new audit campaigns and initiatives, including one on October 5, 2020, that will examine Nonresident Aliens who receive rental income from U.S. real property, and on September 14, 2020, one intended to increase FIRPTA voluntary compliance in connection with the withholding of tax and reporting obligations on the disposition of U.S. real property interests through issue-based examinations and external education. The panel will discuss these and other current developments and also discuss the IRS new Office of Fraud Enforcement and their implications for high wealth foreign and domestic taxpayers.

Moderator: Fred Murray, Special Counsel, Office of Chief Counsel, IRS, Washington, DC

Panelists:
Caroline D. Ciraolo, Partner; Kostelanetz & Fink, LLP, Washington, DC
Steven Toscher, Managing Principal; Hochman Salkin Toscher Perez P.C., Beverly Hills, CA
Clifford Scherwinski, Director; Field Operations GHW & Passthrough Exam Strategy; LB&I Division, IRS, Washington, DC
Deborah Palacheck, Director; Withholding and International Individual Compliance; LB&I Division, IRS, Washington, DC

Click here for more information and to register.