Private wealth tax controversies

Deep experience navigating interactions with taxing authorities

In today’s tax controversy climate, it is more important than ever to understand the important steps of the tax controversy process. Regardless of where an examination starts, the tax controversy process requires careful planning from onset to resolution.​


The Internal Revenue Service and state taxing authorities continue to focus on taxpayers with sophisticated personal and business situations, and private wealth taxpayers are subject to examination from a number of specialized divisions. The Global High Wealth (GHW) industry group was formed by the Internal Revenue Service (IRS) in 2009 with the stated purpose of increasing focus on high-income taxpayers, together with their related entities. In addition, private wealth taxpayers continue to be examined, often very thoroughly, by the Small Business and Self-Employed IRS division. This division conducts all estate and gift examinations and many employment tax examinations, regardless of size. Finally, there are the normal correspondence examinations, most of which are generated by the IRS Service Centers. As a result, high-income taxpayers are much more likely to be examined than lower-income taxpayers.

Private wealth taxpayers benefit by taking steps today to embed best practices in the tax planning and compliance processes to address the needs for necessary documentation if an examination were to occur by a taxing authority.

​IRS interactions can be very challenging, but the Deloitte Tax controversy team guided us through the process and helped us to reach a better outcome than we thought possible.​​

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