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Section on Taxation Round Table: Update on IRS High Net Worth Audit Campaign and Other Initiatives
This roundtable will discuss recent and ongoing IRS tax enforcement measures targeted towards high net worth individuals, including the Global High-Wealth Audits campaign. Attendees will hear about where the IRS is focusing its resources, coordination between civil and criminal investigations, potential effects of the Biden Administration’s push to make high net worth individuals pay their fair share of taxes, and future compliance targets by revenue agents.
About the Presenters
Edward L. Froelich, Of Counsel, Morrison & Foerster LLP
Edward Froelich represents clients in audit and litigation and is the lead of the firm’s Federal tax controversy group. He is a former trial attorney of the Department of Justice Tax Division where he litigated numerous cases, including complex corporate refund cases. In private practice he continues to litigate cases and represents clients in administrative controversies at both the audit and appeals level before the IRS. His experience has been crucial to securing favorable resolutions of matters with the IRS Appeals Office and in the field. Ed represents domestic and foreign public companies, privately-held companies, partnerships, trusts, and individuals. Many of his clients are in the financial, technology, and real estate industries. He has successfully dealt with a variety of issues including international tax, transfer pricing, income tax accounting, employment tax, accounting method and penalty issues. Ed also regularly advises on privilege and work product questions and on various procedural issues including the obligation to file information returns such as those relating to many of the Form 1099 series, FATCA and employment taxes.
Jennifer M. O’Brien, Counsel, Fox Rothschild LLP
Jennifer is an experienced advisor who routinely advises and represents financial institutions and high-net-worth individuals on complex international and federal tax matters. Her practice covers all facets of the tax dispute resolution process, including IRS examinations and appeals, litigation of civil and criminal tax matters, and governmental investigations. With corporate and individual clients spanning five continents, Jennifer has extensive experience managing U.S. compliance and enforcement issues arising from international and offshore circumstances as well as undeclared virtual currency. Having practiced in Switzerland for nearly five years, Jennifer brings a unique perspective to her clients’ dealings with U.S. and foreign tax authorities. She also counsels clients on relinquishment of U.S. citizenship and abandonment of lawful permanent resident status.
Registration & Attendance Information
Call In Information
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+1 571-616-0550
Phone Conference ID: 153 328 787#
Ground Rules
- Statements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.
- No recording devices allowed.
- FBA Tax Section membership is not required to participate, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.
Interested in Speaking? If you are interested in leading a future monthly call, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com.