The IRS understands wealth. They deploy specialized agents, sophisticated data analytics, and targeted strategies to audit high-income earners and individuals with significant assets. You need a tax defense attorney who understands the IRS's playbook—and how to counter it with precision and discretion.
The IRS's Criminal Investigation division and High Income Non-Filer units specifically target individuals and entities with $10 million or more in assets and $1 million or more in reported income. These aren't routine audits. They are surgical, sophisticated examinations designed to expose discrepancies, aggressive positions, and unreported income.
The IRS allocates significantly more resources to auditing high net worth individuals. You face experienced revenue agents, senior technical advisors, and criminal investigators. Your audit will be thorough, expensive, and time-consuming unless you have sophisticated representation.
The IRS uses advanced matching technology to cross-reference income sources, identify unreported transactions, and flag unusual patterns. Your financial complexity doesn't hide issues—it amplifies IRS interest. Early intervention by a skilled attorney can prevent escalation.
The Numbers Don't Lie
IRS data shows that individuals reporting over $1 million in income face audit rates 42 times higher than the general population. The stakes are enormous.
High net worth individuals employ sophisticated tax strategies. The IRS specifically targets these structures. We defend the most complex and contested tax positions:
Multiple LLCs, partnerships, S-corporations, and multi-tiered entities require careful documentation and consistent reporting. The IRS scrutinizes allocation of income, loss deductions, and basis calculations. We defend aggressive but defensible positions and correct positions taken in error before they escalate.
These strategies attract IRS attention. We defend valuations, syndicated easement programs, proper charitable substantiation, and IRC 1031 exchange documentation. If the IRS has already challenged a position, we pursue Appeals or litigation if necessary.
Small captive insurance companies are under intense IRS scrutiny. We address policyholder relationships, reasonable premium payments, actual risk transfer, and economic substantiation. Many micro-captives are now being challenged in litigation. We provide aggressive defense or settlement strategy.
International transactions, payments between related entities, and cross-border structures require documentation and analysis that can withstand IRS examination. We prepare and defend transfer pricing studies, contemporaneous documentation, and economic analyses.
Deferred compensation plans, installment sales, variable prepaid forward contracts, and other timing strategies require precision. We document economic substance, proper reporting, and compliance with technical requirements before and during audit.
International wealth creates FBAR and FATCA exposure. We defend unreported foreign accounts, ensure proper disclosure, and minimize penalties if violations occurred. We also represent clients in IRS and FinCEN matters.
High net worth individuals require discretion. Audit proceedings, settlement negotiations, and aggressive tax positions should not become public. We use attorney-client privilege to shield your communications, strategy, and sensitive financial information from IRS discovery.
All communications with our firm are protected by privilege. The IRS cannot demand your tax advice, strategy discussions, or internal deliberations. We structure our engagement to maximize privilege protection and minimize exposure of sensitive information.
Our analysis, legal strategies, and case evaluations are protected work product. Even if an audit escalates to litigation, these materials remain confidential. This allows candid discussion of aggressive positions and exit strategies without fear of disclosure.
Your audit may be conducted by the IRS office nearest your residence or business. We have relationships with IRS officials, Appeals officers, and tax counsel nationwide. We appear before any audit team, anywhere in the country, from our Irvine, CA office.
We do not publicize client matters or seek publicity for settlements. We focus on efficient, confidential resolution. No press releases. No public commentary. Just discreet, professional defense of your interests.
The best IRS defense is prevention. We work with high net worth individuals to identify exposure, strengthen documentation, and position aggressive strategies to withstand scrutiny before an audit begins.
We review your returns, entity structures, and tax positions. We identify red flags, strengthen documentation, and recommend corrective filings or amendments before the IRS initiates contact. Early action significantly improves outcomes.
Aggressive positions need meticulous support. We prepare contemporaneous documentation, economic analyses, and technical memoranda that demonstrate substantiation. The IRS's own guidance shows that strong documentation reduces assessment risk by up to 40%.
If exposure exists, voluntary disclosure before IRS contact significantly reduces penalties and creates settlement leverage. We evaluate disclosure programs, manage risk, and negotiate with IRS Criminal Investigation if necessary.
How positions are reported on your return matters. We advise on disclosure, Form 8275 substantiation statements, and return footnotes that demonstrate good faith and legal authority. Proper positioning can prevent audit selection entirely.
We develop relationships with IRS personnel, Appeals officers, and Counsel. When your file lands on an agent's desk, they know us. They know we don't play games. This reputation often changes the trajectory of an examination before it begins.
Wealth transfer creates tax audit risk. We structure gifts, trusts, and transfers to minimize exposure. We also prepare for future audits of your estate and descendants by documenting valuation methodologies and transfer pricing from today.
Cassra Minai, Esq. has represented individuals with assets exceeding $100 million and complex multi-state, multi-national tax structures. We understand the IRS's perspective, their audit priorities, and how to negotiate outcomes that protect your wealth.
We don't settle every case. We litigate. We appeal. We contest IRS positions with evidence and legal authority. The IRS knows that we will fight if the position is defensible. This reputation alone often improves settlement offers.
Complex tax law requires specialists. We maintain expertise in transfer pricing, entity classification, micro-captive insurance, conservation easements, and other sophisticated structures. We don't generalize. We deep-dive into technical issues.
When your wealth is under audit, you need to know that your case is handled by an attorney who understands the stakes, respects confidentiality, and will protect your interests with precision and discretion. That's what we deliver.