Tax controversies and the family office

An ounce of prevention is worth a pound of cure

Family offices have seen an increased focus by the IRS on tax controversy. This article provides an overview of some important considerations in light of the current environment and addresses some common questions.

Tax controversies and the family office

Over the past few years, family offices have seen an increased focus by the IRS on tax controversy (a taxing authority’s examination and challenge of an individual’s or entity’s tax position). The formation of the Global High Wealth Industry (GHWI) group by the IRS in 2009 solidified the increased focus on these examinations. Navigating this new environment can be an uncertain time for wealthy families, but we have seen the first such cases undergo this process. 

In this article, we address some of the questions family offices may have regarding the GHWI audit approach with special attention to what we have learned since 2009.

The article discusses:

  • An overview of what the GHWI group is and likelihood of an examination.
  • Initial observations of the group’s results and its approach through activity to date.
  • Common tax issues arising in the GHWI’s enterprise reviews.
  • What to expect and how to manage an examination effectively.
Insights for family offices


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