1 00:00:00,160 --> 00:00:02,400 Speaker 1: Years of budget cuts at the i r S have 2 00:00:02,560 --> 00:00:04,880 Speaker 1: led to a drop in the number of audits. So 3 00:00:04,920 --> 00:00:07,640 Speaker 1: this year the agency will try to keep money flowing 4 00:00:07,680 --> 00:00:10,440 Speaker 1: into the U. S. Treasury by turning up the heat 5 00:00:10,520 --> 00:00:13,680 Speaker 1: on the ultra wealthy and large companies. The i r 6 00:00:13,840 --> 00:00:16,880 Speaker 1: S has revealed only a few details of its plan 7 00:00:16,960 --> 00:00:20,040 Speaker 1: of attack, after all, too much information could give tax 8 00:00:20,079 --> 00:00:25,840 Speaker 1: evaders clues. Joining me is tax attorney Corey Steigle of Hawkman, Salken, Reddick, 9 00:00:25,920 --> 00:00:30,120 Speaker 1: Tasher and Perez Corey. There are lots of rich people, 10 00:00:30,480 --> 00:00:33,640 Speaker 1: lots of large companies. How does the i r S 11 00:00:33,760 --> 00:00:39,040 Speaker 1: decide whom to target? Well, thank you very much. The 12 00:00:39,040 --> 00:00:42,320 Speaker 1: the i r S and the audits today, what they're 13 00:00:42,400 --> 00:00:44,600 Speaker 1: what they're auditing is things that happened in the world 14 00:00:44,600 --> 00:00:47,440 Speaker 1: world stay three years ago or within three years ago, 15 00:00:47,479 --> 00:00:50,400 Speaker 1: because that's what the statue limitations is. So what what 16 00:00:50,479 --> 00:00:52,599 Speaker 1: do we what do we have with the let's say, 17 00:00:52,600 --> 00:00:55,400 Speaker 1: the working rich that have ordinary income, let's say five 18 00:00:55,440 --> 00:00:58,120 Speaker 1: hundred thousand, a million dollars of income. They want to 19 00:00:58,160 --> 00:01:01,440 Speaker 1: offet that income potentially with our losses. So the i 20 00:01:01,560 --> 00:01:04,400 Speaker 1: r S is looking where the money is and challenging 21 00:01:04,480 --> 00:01:07,319 Speaker 1: losses that the taxpayer has, so they might be looking 22 00:01:07,360 --> 00:01:11,640 Speaker 1: at passive losses where you can offset ordinary income. Maybe 23 00:01:11,640 --> 00:01:15,640 Speaker 1: they're looking at hopy losses like say racehorse, racehorses, and 24 00:01:15,680 --> 00:01:18,160 Speaker 1: maybe there's a wall in the orchard with the ranch 25 00:01:18,280 --> 00:01:20,720 Speaker 1: that is a working ranch, there's losses coming from that, 26 00:01:21,120 --> 00:01:23,480 Speaker 1: but various things that are offsetting the income. And with 27 00:01:23,600 --> 00:01:26,200 Speaker 1: the larger businesses, they're also focusing on where they think 28 00:01:26,280 --> 00:01:29,200 Speaker 1: there could be some efficient audits. Maybe they're looking at 29 00:01:29,280 --> 00:01:32,479 Speaker 1: methods of accounting for real estate losses. Maybe they're looking 30 00:01:32,520 --> 00:01:35,640 Speaker 1: at a tax credit. But at the end of the day, 31 00:01:35,720 --> 00:01:37,640 Speaker 1: when you when you look at it, much of the 32 00:01:38,120 --> 00:01:43,039 Speaker 1: taxes are paid by the wealthy and as a result, 33 00:01:43,160 --> 00:01:46,640 Speaker 1: that's why they're focusing on the on the wealthy. Now, 34 00:01:46,800 --> 00:01:49,720 Speaker 1: will the i r S send out one of those 35 00:01:49,760 --> 00:01:54,040 Speaker 1: automated responses first, those automated questions asking you for more 36 00:01:54,080 --> 00:01:56,960 Speaker 1: information and then you get to provided or is it 37 00:01:57,000 --> 00:02:01,000 Speaker 1: a full on audit right away? Well, hopefully you do 38 00:02:01,120 --> 00:02:04,320 Speaker 1: only get a desk out it, which is perhaps something 39 00:02:04,480 --> 00:02:06,720 Speaker 1: was identified in the i r S system under their 40 00:02:06,720 --> 00:02:09,040 Speaker 1: ditch score, which we all can't know because we don't 41 00:02:09,080 --> 00:02:10,760 Speaker 1: want to, you know, they don't want us to know 42 00:02:10,840 --> 00:02:13,120 Speaker 1: everything that they're if they're looking that they're looking at, 43 00:02:13,160 --> 00:02:15,600 Speaker 1: but they'll hopefully send out a letter and follow up 44 00:02:15,600 --> 00:02:18,400 Speaker 1: on a specific thing. You give the information, you're done, 45 00:02:18,800 --> 00:02:20,720 Speaker 1: but hopefully what you don't have is one of their 46 00:02:20,760 --> 00:02:24,640 Speaker 1: Wealth Squad audits, which are really focused on the ultra 47 00:02:24,760 --> 00:02:28,240 Speaker 1: rich being stay over five five million dollars of income 48 00:02:28,600 --> 00:02:32,560 Speaker 1: a year. Let's talk about the not only the Wealth Squad, 49 00:02:32,639 --> 00:02:36,600 Speaker 1: but the Large Business and International Division, which focuses on 50 00:02:36,720 --> 00:02:40,600 Speaker 1: large companies and the ultra wealthy and includes the Wealth Squad. 51 00:02:40,880 --> 00:02:44,880 Speaker 1: And they announced thirteen new campaigns. Tell me about some 52 00:02:45,000 --> 00:02:49,360 Speaker 1: of them. Well, one of the campaigns is focused on 53 00:02:49,400 --> 00:02:54,079 Speaker 1: the high wealth earners. And basically what it is that 54 00:02:54,200 --> 00:02:55,960 Speaker 1: the at the beginning of the audit you get a 55 00:02:56,160 --> 00:02:59,919 Speaker 1: very extensive I d R that basically for for well, 56 00:03:00,040 --> 00:03:03,600 Speaker 1: the individual speaks out everything they have, looks for all 57 00:03:03,600 --> 00:03:06,960 Speaker 1: their sources of income, all their assets, if they own 58 00:03:06,960 --> 00:03:10,239 Speaker 1: an interest in and entity over they not only ask 59 00:03:10,280 --> 00:03:13,239 Speaker 1: about their activity, but the last about other board members. 60 00:03:13,280 --> 00:03:15,760 Speaker 1: So what you have is these very expanse expanse of 61 00:03:15,919 --> 00:03:18,639 Speaker 1: LB and I audits. They're almost like tentacles that reach 62 00:03:18,680 --> 00:03:21,400 Speaker 1: out not just to the save the ten forty, but 63 00:03:21,440 --> 00:03:25,240 Speaker 1: also to the businesses of the wealthy person. So now 64 00:03:25,880 --> 00:03:29,000 Speaker 1: is there a red flag that signals that they're going 65 00:03:29,000 --> 00:03:31,760 Speaker 1: to go after these companies or is it just the 66 00:03:31,840 --> 00:03:36,080 Speaker 1: size or the you know, or the wealth of the individual. Well, 67 00:03:36,200 --> 00:03:39,040 Speaker 1: LB and I focuses on on businesses that are over 68 00:03:39,800 --> 00:03:44,000 Speaker 1: ten million in assets or income UM so and and 69 00:03:44,160 --> 00:03:48,520 Speaker 1: it's it's focused on you know, very high um income 70 00:03:48,560 --> 00:03:51,400 Speaker 1: areas that are going to generate a lot of UM tax. 71 00:03:51,440 --> 00:03:55,880 Speaker 1: For instance, they have industry groups, heavy manufacturing, natural resources, retailers, 72 00:03:55,960 --> 00:03:57,560 Speaker 1: and when you look at the returns that they get 73 00:03:57,600 --> 00:04:00,960 Speaker 1: for every hour that their oddity and there they're quite significant. 74 00:04:01,000 --> 00:04:03,560 Speaker 1: So the I R S is is going to focus 75 00:04:03,560 --> 00:04:06,400 Speaker 1: and focus on these. But when you're looking at a 76 00:04:06,400 --> 00:04:09,560 Speaker 1: at a at a wealthy individual um at the end 77 00:04:09,560 --> 00:04:13,040 Speaker 1: of the day, your income alone may well be more 78 00:04:13,120 --> 00:04:14,920 Speaker 1: likely to trigger an audit because you look at a 79 00:04:14,960 --> 00:04:18,000 Speaker 1: typical person, the audit rate is say one percent, a 80 00:04:18,000 --> 00:04:21,440 Speaker 1: little under one percent. You start to make you start 81 00:04:21,480 --> 00:04:24,159 Speaker 1: to make stay two hundred thousand, which is what the 82 00:04:24,160 --> 00:04:26,080 Speaker 1: I R S starts to stay is rich. You're up 83 00:04:26,080 --> 00:04:28,960 Speaker 1: to two you're making five million, you up to eleven percent, 84 00:04:29,000 --> 00:04:31,120 Speaker 1: you're over ten million, you have a sixty percent of 85 00:04:31,160 --> 00:04:33,160 Speaker 1: an audit. That's a couple of years ago. We don't 86 00:04:33,200 --> 00:04:35,760 Speaker 1: have the most recent data yet the i r S 87 00:04:35,760 --> 00:04:37,600 Speaker 1: publishes it. But the fact of the matter is if 88 00:04:37,600 --> 00:04:40,760 Speaker 1: you're making more income, that alone is enough to give 89 00:04:40,760 --> 00:04:43,640 Speaker 1: you a higher chance of having an audit. So would 90 00:04:43,640 --> 00:04:47,560 Speaker 1: you advise your clients or are other tax attorneys advising 91 00:04:47,640 --> 00:04:51,680 Speaker 1: clients to be less creative about how they lower their 92 00:04:51,760 --> 00:04:54,520 Speaker 1: tax bills. Well, at the end of the day, the 93 00:04:54,560 --> 00:04:56,640 Speaker 1: i r S is trying to administer a collection at 94 00:04:56,680 --> 00:04:59,560 Speaker 1: three trillions of taxes and they have fewer people to 95 00:04:59,600 --> 00:05:02,160 Speaker 1: do the at the job. So one of the reasons 96 00:05:02,160 --> 00:05:05,000 Speaker 1: why they're focusing on this or for their business reasons 97 00:05:05,040 --> 00:05:07,960 Speaker 1: is the term. So absolutely the service wants people to 98 00:05:08,040 --> 00:05:10,880 Speaker 1: know that there's wealth squads out there focusing on on 99 00:05:11,040 --> 00:05:13,920 Speaker 1: people with very complex tax affairs. But my advice would 100 00:05:13,920 --> 00:05:16,320 Speaker 1: be to rely on your your cp A, your enrolled 101 00:05:16,320 --> 00:05:19,160 Speaker 1: agents that's preparing your returns. And if it's too good 102 00:05:19,200 --> 00:05:21,120 Speaker 1: to be true, it sounds too good to be true, 103 00:05:21,160 --> 00:05:25,839 Speaker 1: maybe it is. We have about thirty seconds here. What 104 00:05:25,839 --> 00:05:31,560 Speaker 1: what about repatriation? Yes, I'll tell you that a lot 105 00:05:31,600 --> 00:05:34,440 Speaker 1: of taxpayers are just and these are people that are 106 00:05:34,440 --> 00:05:37,240 Speaker 1: in audits and the tires have been kicked the last 107 00:05:37,240 --> 00:05:39,719 Speaker 1: couple of years. People are very interested to see what's 108 00:05:39,720 --> 00:05:43,400 Speaker 1: going to happen with with some benefits for repatriation, like 109 00:05:43,720 --> 00:05:46,480 Speaker 1: is it possible to wait and have a better environment 110 00:05:46,560 --> 00:05:48,760 Speaker 1: to repatriate money. But I'll tell you one of the 111 00:05:48,839 --> 00:05:50,440 Speaker 1: things that the I R. S Is looking at is 112 00:05:50,880 --> 00:05:54,039 Speaker 1: do you have offshore accounts? Were their transfers outside of 113 00:05:54,080 --> 00:05:56,760 Speaker 1: the US. So you know that's gonna be something they're 114 00:05:56,760 --> 00:05:58,280 Speaker 1: going to be looking at. But it's also going to 115 00:05:58,320 --> 00:06:01,080 Speaker 1: be something that taxpayers are looking for a potentially in 116 00:06:01,120 --> 00:06:03,480 Speaker 1: the future to maybe bring back some of that money. 117 00:06:03,600 --> 00:06:07,080 Speaker 1: We'll see what happens as taxis and approaches. Thanks so 118 00:06:07,160 --> 00:06:11,080 Speaker 1: much for joining us on Bloomberg Law. That's Corey Steigel 119 00:06:11,160 --> 00:06:13,960 Speaker 1: of Hochmann, Salkin, Reddick, Tosher, and Perez