"Hot Tax Controversy Issues for the High Net Worth Taxpayer," Estate Planning Conference
With audits down, the IRS is focusing on program-type audit issues like conservation easements and offshore matters. Additional program audits include heightened scrutiny for offshore participants seeking streamlined relief as well as micro-captives. Auditors are urged to challenge purchase price allocations under the change in method of accounting rules. Non-program issues focus on challenging losses either based on the material participation rules or lack of business purpose.
For more information on the Estate Planning Conference, please visit The Georgia Society of CPAs website.