New IRS Holistic Audit ProgramNew IRS Holistic Audit Program

Stephanie E. Heilborn, Kathryn Keneally & Lindsay H. Brown

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 program and how taxpayers and their advisors can plan defensively for a holistic audit.

Creation of the Program

IRS Commissioner Douglas Shulman announced the creation of the program in a speech ...