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Focus On High Net Worth Nonfilers

By Megan L. Brackney
Tax Notes Federal
September 28, 2020

In a Sept. 28, 2020 Tax Notes article entitled, “Focus on High-Net-Worth Nonfilers,” Megan Brackney examines what taxpayers who fail to file returns can expect from the IRS, and she offers strategies to avoid some of the harsher potential consequences of long- term delinquency.


In February the IRS announced a new initiative to increase tax compliance and enforcement, specifically for high-net-worth nonfilers. The IRS announced that it will visit more taxpayers who have not filed tax returns for prior years, and increase its use of “data analytics, research, and new compliance strategies.” These strategies include:

• increasing the identification of and case creation for individual and business nonfilers;
• using the Automated Substitute for Return program for taxpayers who have not filed tax returns but for whom third-party reporting indicates a significant income tax liability; and
• using the Delinquent Return Refund Hold program, which systemically holds an individual taxpayer’s income tax refund when their account has at least one unfiled tax return within a five-year period.

Given that we should expect to see increased enforcement actions against nonfilers and that they (and some of our clients — and future clients) may be getting a visit from the IRS, this article examines what taxpayers can expect and offers strategies to avoid some of the harsher possible consequences of long-term delinquency.

Click here to access the full article