The federal government recently has enacted several laws increasing the reporting obligations of both U.S. resident and non-resident taxpayers and imposing additional taxes and penalties on non-compliant taxpayers. But how can the Internal Revenue Service be sure that taxpayers are fulfilling these requirements? The IRS has unveiled a new “holistic audit” program designed to increase compliance among high-net-worth individuals. Let's look at the program, the legal framework underpinning the ...

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