Thursday, May 27, 2010
Newly created exam teams will scrub wealthy taxpayers' hedge funds, trusts and foreign accounts.
Those who by anyone’s measure would be considered wealthy, should be on notice: How you acquired and now maintain the wherewithal to be so labeled may soon be called into question by the IRS. That’s not to say that the questions can’t be answered and the matter closed with no further tax due, but the means to that end could get complicated.
Last Fall, IRS Commissioner Doug Shulman unveiled his vision for a Global High Wealth Exam Group--the latest addition to the agency’s arsenal of compliance strategies. Its goal is to ensure that these high-end Form 1040 filers are not shirking their federal tax responsibilities. While the exact amount of “wealth” that will arouse IRS interest was not disclosed, the Commissioner suggested a threshold in the neighborhood of tens of million of dollars. According to the most recently released IRS estimates, in 2004 there were approximately 47,000 individual taxpayers with a net worth of $20,000,000 or more. ...
This will not be a kick-the-tires type of exam. Instead, think in terms of a major overhaul. Global High Wealth taxpayers and their representatives should expect to confront teams of revenue agents, partnership experts, and international examiners prepared to scrub not only the Forms 1040 and the attached schedules but also any and all related returns. In the background will be specialists in such areas as financial instruments; exempt organizations; retirement plans (whether individually maintained or employer sponsored) and insurance and annuity arrangements. And for those who like to play on the edge, do not overlook the possibility of a criminal investigation agent being asked to join the group. The bottom line is that these teams will have access to whatever resources they need.
Going Concern, Memo to Rich People: Gird Your Loins for the IRS ‘Wealth Squads’:
For those of you keeping score, the ballpark figure of “wealth” is “in the neighborhood of tens of million of dollars,” according to IRS Commish Doug Shulman’s best guess. So if this is you, the time is nigh. You peasants whose net worth falls into the seven figure range probably can rest easy but don’t get too comfortable, you’re still at risk.
And don’t think that this will be a friendly visit between you, your CPA and an IRS representative. No, this will likely be a financial strip search that will be topped off with a latex surgical glove moseying around your nether regions.