The IRS Global High Wealth Program: How UHNWIs Can Resolve Investigations

Last Updated: October 2026

Key Takeaways

The Global High Wealth (GHW) Program, established in 2009, operates within the IRS Large Business & International (LB&I) Division’s Pass-Through Entity (PTE) Practice Area and conducts enterprise-wide examinations of high-net-worth individuals and the entities they control, as described in I.R.M. 4.52.1 .
Under the IRS’s Strategic Operating Plan, audit rates for individuals with total positive income exceeding $10 million are projected to reach 16.5% by 2026, up from 11% in 2019.
In United States v. Clarke, 573 U.S. 248 (2014), the Supreme Court held that a taxpayer may examine IRS officials about the reasons for issuing a summons only if the taxpayer points to specific facts or circumstances plausibly raising an inference of bad faith.
Under I.R.C. § 6751(b)(1), no penalty may be assessed unless the initial determination is personally approved in writing by the immediate supervisor of the individual making the determination, per Treas. Reg. § 301.6751(b)-1.
The GHW Program has faced significant staffing reductions, losing 38% of its employees since January 2025, which has resulted in stalled audits and reduced expertise .

Answer Box

The IRS Global High Wealth (GHW) Program is an enforcement initiative within the IRS Large Business & International (LB&I) Division’s Pass-Through Entity (PTE) Practice Area that conducts enterprise-wide examinations of individuals with total positive income exceeding $10 million and the entities they control, including trusts, partnerships, S corporations, and private foundations, under the authority of I.R.C. § 7602 and I.R.M. 4.52.1. Resolution strategies include Fast Track Settlement under I.R.M. 8.26.2, IRS Independent Office of Appeals proceedings under I.R.C. § 7801(a)(1), and Tax Court litigation under I.R.C. § 6213(a). The burden of proof generally remains on the taxpayer under Tax Court Rule 142(a), though it may shift under I.R.C. § 7491(a) if the taxpayer introduces credible evidence and meets applicable net worth requirements.

Introduction

The IRS Global High Wealth (GHW) Program represents the most sophisticated enforcement apparatus the IRS deploys against ultra-high-net-worth individuals. Unlike a conventional examination limited to a single Form 1040, a GHW audit is an enterprise-wide examination that begins with the individual’s return and radiates outward to encompass every entity the taxpayer controls: irrevocable trusts, family limited partnerships, S corporations, LLCs, controlled foreign corporations, charitable foundations, and family office investment vehicles.

The Internal Revenue Code at I.R.C. § 7602 grants the IRS broad authority to examine books, records, and witnesses for the purpose of ascertaining tax liability . Below the Code, Treasury Regulations at Treas. Reg. § 301.7602-1 implement this examination authority. The Internal Revenue Manual at I.R.M. 4.52.1, revised December 12, 2025, establishes the procedural framework for the GHW Program . Judicial decisions, most notably United States v. Clarke, 573 U.S. 248 (2014), define the limits of IRS summons authority. This article maps the authority hierarchy governing the GHW Program, the binding effect of each authority, and the practical strategies for resolving investigations.

[Internal Link: IRS Independent Office of Appeals Procedures]
[External Link: IRS.gov — Global High Wealth Program IRM]

Query Fan-Out Map

The following discrete questions are answered explicitly in this article:

Query Type	Question	Section
Definitional	What is the IRS Global High Wealth Program?	§ What Is the GHW Program?
Threshold	What income level triggers a GHW audit?	§ Threshold Table
Procedural	How does a GHW audit begin?	§ Audit Lifecycle
Comparative	GHW audit vs. standard IRS audit?	§ Comparison Table
Exception	When does the GHW Program not apply?	§ Eligibility Requirements
Authority	Is I.R.M. 4.52.1 binding on the IRS?	§ Binding Effect
Penalty	What penalties can the GHW Program impose?	§ Penalty Table
Temporal	Did the GHW Program change after 2025?	§ Sunset and Transition
Procedural	How do you resolve a GHW investigation?	§ Practical Application
Authority	Is United States v. Clarke binding on the IRS?	§ Precedential Value
Penalty	What is the accuracy-related penalty for GHW audits?	§ Penalty Table
Threshold	What is the 2026 audit rate for $10M+ earners?	§ Threshold Table
Procedural	How do you appeal a GHW audit determination?	§ Appeals
Exception	When can a taxpayer challenge a GHW summons?	§ Summons Enforcement
Temporal	Is the GHW Program still active in 2026?	§ Current Scope

What Is the IRS Global High Wealth Program?

Direct answer: The IRS Global High Wealth (GHW) Program is an enterprise-wide examination initiative within the IRS Large Business & International (LB&I) Division’s Pass-Through Entity (PTE) Practice Area that targets individuals with total positive income exceeding $10 million and the entities they control, including trusts, partnerships, S corporations, and private foundations, under the authority of I.R.C. § 7602 and I.R.M. 4.52.1. The program was established in 2009 to take a holistic approach to examining the complete financial picture of high-wealth individuals .

Statutory Basis

I.R.C. § 7602(a) authorizes the IRS “to examine any books, papers, records, or other data which may be relevant or material” to ascertain the correctness of any return and “to summon the person liable for tax or required to perform the act” . I.R.C. § 7605 governs the time and place of examination. I.R.C. § 7609 provides special procedures for third-party summonses. The GHW Program operates under these authorities, with I.R.M. 4.52.1 providing the administrative framework .

Historical Development

The GHW Program was established in 2009 by the IRS Large Business and International (LB&I) Division to address the compliance risks posed by high-wealth taxpayers whose financial affairs span multiple entities and jurisdictions . The program’s guiding philosophy is enterprise-wide examination: rather than examining a single return in isolation, the GHW team examines the complete financial ecosystem of the taxpayer, including flow-through entities, trusts and estates, and cross-border holdings . I.R.M. 4.52.1 was first added in 2013 and has been updated periodically, most recently on December 12, 2025.

Current Scope

For 2026, the GHW Program targets individuals with total positive income exceeding $10 million . The IRS’s Strategic Operating Plan projects audit rates for this population to reach 16.5% by 2026, up from 11% in 2019. The program evaluates the entire financial ecosystem of the high-net-worth taxpayer, including flow-through entities, trusts and estates, and cross-border holdings, with multidisciplinary examination teams combining tax, valuation, and economic professionals .

The GHW Program has faced significant staffing reductions. The unit lost 38% of its employees since January 2025, declining from 353 employees to approximately 219, which has resulted in stalled audits and reduced expertise . Despite these reductions, the IRS continues to use advanced analytics and artificial intelligence to identify high-risk returns .

Entity Reference Table

Entity	Full Name	Type	Role in This Article
I.R.C. § 7602	Examination authority	Primary authority	Authorizes IRS examinations and summonses
I.R.C. § 7605	Time and place of examination	Primary authority	Governs examination procedures
I.R.C. § 7609	Third-party summonses	Primary authority	Special procedures for third-party summonses
I.R.C. § 6751(b)	Supervisory approval	Primary authority	Requires written approval before penalty assessment
I.R.C. § 7491	Burden of proof	Primary authority	Shifts burden to IRS if credible evidence introduced
I.R.M. 4.52.1	GHW Program Procedures	IRS guidance	Establishes GHW program framework
United States v. Clarke	573 U.S. 248 (2014)	Judicial authority	Defines standard for challenging IRS summonses
LB&I Division	Large Business & International	IRS operating division	Parent division of the GHW Program
PTE Practice Area	Pass-Through Entity Practice Area	IRS practice area	Oversees GHW Program operations
GHW WLS	GHW Workload Services	IRS support function	Manages document processing and case management

Binding Effect and Legal Weight

Direct answer: The Internal Revenue Code at I.R.C. § 7602 binds the IRS, courts, and taxpayers as primary statutory authority. Treasury Regulations at Treas. Reg. § 301.7602-1 are legislative regulations that carry the force of law. United States v. Clarke, 573 U.S. 248 (2014), is binding on all courts as a Supreme Court decision. I.R.M. 4.52.1 binds IRS employees but does not create enforceable rights for taxpayers. The burden of proof generally remains on the taxpayer under Tax Court Rule 142(a) .

Who Is Bound

Authority	Binds IRS	Binds Courts	Binds Taxpayers
I.R.C. § 7602	Yes	Yes	Yes
Treas. Reg. § 301.7602-1	Yes	Yes (legislative regulation)	Yes
I.R.C. § 6751(b)	Yes	Yes	Yes
United States v. Clarke, 573 U.S. 248 (2014)	Yes	Yes	Yes
I.R.M. 4.52.1	Yes	No	No
Tax Court Rule 142(a)	N/A	Yes	Yes

Precedential Value

The Supreme Court’s decision in United States v. Clarke, 573 U.S. 248 (2014), is binding on all federal courts. The Court held that a taxpayer has a right to conduct an examination of IRS officials regarding their reasons for issuing a summons when he points to specific facts or circumstances plausibly raising an inference of bad faith. The Eleventh Circuit’s decision in United States v. Clarke, 732 F.3d 1238 (11th Cir. 2013), was vacated by the Supreme Court, but the underlying principles regarding summons enforcement under United States v. Powell, 379 U.S. 48 (1964), remain binding.

Primary vs. Secondary Authority

The Internal Revenue Code and Treasury Regulations are primary authority. Judicial decisions interpreting those provisions are also primary authority. I.R.M. 4.52.1 is an internal management document that binds IRS employees in processing cases but does not create enforceable rights for taxpayers. The GHW Workload Services (WLS) function operates under I.R.M. 4.52.1 and provides support for document processing and case management .

Key Authorities and Cases

Direct answer: The primary authorities governing the GHW Program are I.R.C. § 7602 (examination authority), I.R.C. § 7605 (time and place of examination), and I.R.C. § 7609 (third-party summonses). Key judicial decisions include United States v. Clarke, 573 U.S. 248 (2014), and United States v. Powell, 379 U.S. 48 (1964). The governing IRS guidance is I.R.M. 4.52.1 (GHW Program Processes and Procedures) and I.R.M. 8.26.2 (Fast Track Settlement).

Statutory Authority

Statute	Subject	Application
I.R.C. § 7602	Examination authority	Authorizes IRS to examine books, records, and witnesses
I.R.C. § 7605	Time and place of examination	Governs examination procedures and taxpayer rights
I.R.C. § 7609	Third-party summonses	Provides notice and intervention rights
I.R.C. § 6751(b)	Supervisory approval	Requires written approval before penalty assessment
I.R.C. § 7491	Burden of proof	Shifts burden to IRS if credible evidence introduced
I.R.C. § 6213(a)	Deficiency procedures	Allows taxpayer to petition Tax Court before assessment
I.R.C. § 7801(a)(1)	Appeals authority	Establishes Independent Office of Appeals

Treasury Regulations

Regulation	Subject	Application
Treas. Reg. § 301.7602-1	Examination of books and witnesses	Implements § 7602 examination authority
Treas. Reg. § 301.6751(b)-1	Supervisory approval	Governs timing of penalty approval
Treas. Reg. § 301.7605-1	Time and place of examination	Governs examination procedures

Judicial Decisions

Case	Citation	Holding
United States v. Clarke	573 U.S. 248 (2014)	Taxpayer may examine IRS officials only if specific facts plausibly raise inference of bad faith
United States v. Powell	379 U.S. 48 (1964)	Establishes four-part test for summons enforcement
Sego v. Commissioner	114 T.C. 604 (2000)	Abuse of discretion standard for Appeals determinations
Golsen v. Commissioner	54 T.C. 742 (1970), aff’d, 445 F.2d 985 (10th Cir. 1971)	Tax Court follows law of circuit to which appeal would lie

IRS Guidance

Guidance	Subject	Key Provision
I.R.M. 4.52.1	GHW Program	Enterprise-wide examination procedures
I.R.M. 8.26.2	Fast Track Settlement	Expedited dispute resolution
I.R.M. 4.52.1.5.2	IDR Responses	Document processing procedures
I.R.M. 4.52.1.6	BBA & ILSC	Partnership audit procedures

Summary Table of Authorities

Authority	Type	Binding Effect	Citation
I.R.C. § 7602	Primary (statutory)	Binds all	26 U.S.C. § 7602
Treas. Reg. § 301.7602-1	Primary (legislative)	Binds all	26 C.F.R. § 301.7602-1
United States v. Clarke	Primary (judicial)	Binds all	573 U.S. 248 (2014)
United States v. Powell	Primary (judicial)	Binds all	379 U.S. 48 (1964)
I.R.M. 4.52.1	IRS guidance	Binds IRS	Internal Revenue Manual

Threshold Table: GHW Audit Triggers and Penalties (2026)

Category	Threshold / Rate	Authority	Notes
GHW audit target	Total positive income > $10M	I.R.M. 4.52.1	Enterprise-wide examination
2026 audit rate projection	16.5%	IRS Strategic Operating Plan	Up from 11% in 2019
Accuracy-related penalty	20% of underpayment	I.R.C. § 6662(a)	40% for gross valuation misstatement
Fraud penalty	75% of underpayment	I.R.C. § 6663	Burden on IRS to prove fraud
Supervisory approval	Written approval required	I.R.C. § 6751(b)(1)	Per Treas. Reg. § 301.6751(b)-1
Burden shifting	Credible evidence required	I.R.C. § 7491(a)	Net worth limits apply
Tax Court petition	90 days from notice	I.R.C. § 6213(a)	150 days if outside U.S.

Practical Application in Tax Practice

Direct answer: The practical framework for resolving GHW investigations requires a four-phase approach: (1) pre-audit preparation to identify risk areas and organize documentation; (2) examination management using the I.R.M. 4.52.1 IDR response procedures and United States v. Clarke, 573 U.S. 248 (2014), for summons challenges; (3) administrative resolution through Fast Track Settlement under I.R.M. 8.26.2 or the IRS Independent Office of Appeals under I.R.C. § 7801(a)(1); and (4) litigation in the U.S. Tax Court under I.R.C. § 6213(a) if administrative resolution fails.

Research

Effective research begins with the Internal Revenue Code at I.R.C. § 7602 (examination authority) and I.R.C. § 6751(b) (supervisory approval). Practitioners must then consult Treas. Reg. § 301.7602-1 for examination procedures and I.R.M. 4.52.1 for GHW-specific processes. The Supreme Court’s decision in United States v. Clarke, 573 U.S. 248 (2014), provides the standard for challenging IRS summonses, requiring specific facts or circumstances plausibly raising an inference of bad faith.

Audit

During a GHW examination, the IRS issues Information Document Requests (IDRs) under I.R.M. 4.52.1.5.2. The GHW Workload Services (WLS) function manages document processing, and IDR responses must be submitted through established channels . The IRS may also issue summonses under I.R.C. § 7602 to third parties. Under United States v. Powell, 379 U.S. 48 (1964), the IRS must show that the summons is issued for a legitimate purpose, the information sought is relevant, the IRS does not already possess the information, and the administrative steps required by the Code have been followed.

Appeals

If the examiner proposes adjustments, the taxpayer may request a conference with the IRS Independent Office of Appeals under I.R.C. § 7801(a)(1). The Appeals officer may consider hazards of litigation under I.R.M. 8.11.1.2.7.5(1) and may settle the case on a basis that fairly reflects the relative merits of the opposing positions. For issues identified during the examination, the taxpayer may request Fast Track Settlement under I.R.M. 8.26.2 to resolve disputes before the 30-day letter is issued.

Litigation

If Appeals sustains the deficiency, the taxpayer may petition the U.S. Tax Court within 90 days under I.R.C. § 6213(a). The taxpayer bears the burden of proof under Tax Court Rule 142(a) , though the burden may shift under I.R.C. § 7491(a) if the taxpayer introduces credible evidence and meets applicable net worth requirements. Under Golsen v. Commissioner, 54 T.C. 742 (1970), aff’d, 445 F.2d 985 (10th Cir. 1971), the Tax Court follows the law of the circuit to which an appeal would lie.

Planning Strategies

Factor	Strategy	Authority
Pre-audit documentation	Organize records for all enterprise entities	I.R.M. 4.52.1
IDR management	Respond timely; use draft IDR procedures	I.R.M. 4.52.1.5.2
Summons challenge	Document specific facts showing bad faith	United States v. Clarke
Fast Track Settlement	Resolve issues during examination	I.R.M. 8.26.2
Penalty defense	Challenge supervisory approval under § 6751(b)	I.R.C. § 6751(b)(1)
Burden shifting	Introduce credible evidence; meet net worth limits	I.R.C. § 7491(a)

Comparison Table: GHW Audit vs. Standard Audit

Feature	GHW Enterprise Audit	Standard IRS Audit
Target	Total positive income > $10M	Any income level
Scope	Entire financial ecosystem	Single return or issue
Entities examined	Trusts, partnerships, S corps, CFCs, foundations	Taxpayer’s return only
Team composition	Multidisciplinary: examiners, economists, valuation experts	Revenue agent
IDR volume	Dozens of IDRs covering all entities	Limited to return items
Authority	I.R.M. 4.52.1	I.R.M. 4.10
Resolution pathways	Fast Track, Appeals, Tax Court	Appeals, Tax Court

Interaction with Other Authorities

Direct answer: The Internal Revenue Code at I.R.C. § 7602 sits at the apex of the GHW authority hierarchy, followed by Treasury Regulations at Treas. Reg. § 301.7602-1 , then Supreme Court decisions such as United States v. Clarke, 573 U.S. 248 (2014), and finally I.R.M. 4.52.1 . When an I.R.M. provision conflicts with the statute or regulation, the statute or regulation controls.

Higher Authority

The Internal Revenue Code at I.R.C. § 7602 grants the IRS examination authority. Treas. Reg. § 301.7602-1 implements this authority and carries the force of law. The Supreme Court’s decisions in United States v. Clarke, 573 U.S. 248 (2014), and United States v. Powell, 379 U.S. 48 (1964), establish the standards for summons enforcement. I.R.C. § 6751(b) requires written supervisory approval before penalty assessment.

Lower Authority

I.R.M. 4.52.1 binds IRS employees in GHW examination procedures but does not create enforceable rights for taxpayers. I.R.M. 8.26.2 provides Fast Track Settlement procedures. The GHW Workload Services (WLS) function operates under I.R.M. 4.52.1 and manages document processing and case management .

Conflict Resolution

The resolution rule is: Statute > Legislative Regulation > Supreme Court Decision > Circuit Court Decision > Tax Court Decision > I.R.M. If an I.R.M. provision directs examiners to apply a standard inconsistent with the statute or regulation, the statute or regulation controls. If a Tax Court decision conflicts with a Circuit Court decision within the circuit to which the case is appealable, the Circuit Court decision controls under Golsen v. Commissioner, 54 T.C. 742 (1970), aff’d, 445 F.2d 985 (10th Cir. 1971).

Sunset and Transition Rules

I.R.M. 4.52.1 was revised on December 12, 2025, with updates to program scope, population identification, workload development, and IDR processing procedures .
The GHW Program remains active in 2026, though staffing reductions have affected its capacity .
The IRS Strategic Operating Plan projects audit rates for individuals with income over $10 million to reach 16.5% by 2026.

Common Errors and Pitfalls

Failing to organize documentation across all enterprise entities before the examination begins. GHW audits are enterprise-wide, and the IRS will request records for trusts, partnerships, S corporations, and foundations simultaneously .
Assuming the burden of proof shifts to the IRS automatically. Under I.R.C. § 7491(a) , the burden shifts only if the taxpayer introduces credible evidence and meets the net worth limitation for non-individual taxpayers.
Failing to challenge the penalty on procedural grounds. Under I.R.C. § 6751(b)(1) , the IRS must obtain written supervisory approval before assessing a penalty. Failure to do so is a complete defense to the penalty.
Ignoring the standard for challenging a GHW summons. Under United States v. Clarke, 573 U.S. 248 (2014), a bare allegation of improper purpose is insufficient; the taxpayer must point to specific facts or circumstances plausibly raising an inference of bad faith.
Failing to use Fast Track Settlement. Under I.R.M. 8.26.2, the taxpayer may request Fast Track Settlement to resolve issues during the examination rather than waiting for the 30-day letter and formal Appeals process.
Missing the 30-day letter deadline. If the examination results in proposed adjustments, the taxpayer has 30 days from the 30-day letter to file a written protest with Appeals. Failure to do so results in the issuance of a Notice of Deficiency and loss of the administrative appeal opportunity.
Underestimating the impact of staffing reductions. The GHW Program has lost 38% of its employees since January 2025, which may affect audit timelines but does not reduce the IRS’s substantive enforcement authority .

What This Article Does Not Cover

This article does not address:

Criminal tax prosecution defense strategy: The defense of criminal tax charges under I.R.C. § 7201 and 18 U.S.C. § 371 requires separate constitutional and evidentiary analysis.
State tax audits of high-net-worth individuals: State taxing authorities have separate examination procedures and standards.
International information return penalties: Forms 5471, 5472, 8865, and 3520 have distinct penalty regimes under I.R.C. §§ 6038, 6038A, 6046, 6677.
FBAR penalty appeals: The appeal of FBAR penalties under 31 U.S.C. § 5321 is governed by I.R.M. 8.11.6 and involves separate procedures.
Estate and gift tax valuation disputes: While the GHW Program examines transfer tax issues, the underlying valuation methodologies and I.R.C. § 2031 appraisal standards are not covered in detail.
Post-Appeals mediation and arbitration: The specific procedures for Post-Appeals Mediation (PAM) and Arbitration under I.R.M. 8.26.2 are beyond the scope of this article.

Frequently Asked Questions

What is the IRS Global High Wealth Program and who does it target?

The IRS Global High Wealth (GHW) Program is an enterprise-wide examination initiative within the IRS Large Business & International (LB&I) Division’s Pass-Through Entity (PTE) Practice Area that targets individuals with total positive income exceeding $10 million and the entities they control, including trusts, partnerships, S corporations, and private foundations . Under I.R.M. 4.52.1, the GHW Program evaluates the entire financial ecosystem of the high-net-worth taxpayer, including flow-through entities, trusts and estates, and cross-border holdings .

What is the 2026 audit rate for individuals earning over $10 million?

Under the IRS’s Strategic Operating Plan, audit rates for individuals with incomes over $10 million are projected to reach 16.5% by 2026, up from 11% in 2019. For large complex partnerships, audit rates are projected to increase from 0.1% to 1% by 2026 . The GHW Program uses advanced analytics and artificial intelligence to identify high-risk returns .

Can I challenge a GHW summons issued to a third party?

Yes, but the standard is demanding. Under United States v. Clarke, 573 U.S. 248 (2014), a taxpayer has the right to examine IRS officials regarding their reasons for issuing a summons only if the taxpayer points to specific facts or circumstances plausibly raising an inference of bad faith. A bare allegation of improper purpose is insufficient. The taxpayer must also satisfy the United States v. Powell, 379 U.S. 48 (1964), requirements for challenging summons enforcement.

What penalties can the GHW Program impose?

The GHW Program can impose the 20% accuracy-related penalty under I.R.C. § 6662(a) , increased to 40% for gross valuation misstatements under I.R.C. § 6662(h) or undisclosed foreign assets under I.R.C. § 6662(i) . The 75% fraud penalty under I.R.C. § 6663 applies to fraudulent underpayments. Under I.R.C. § 6751(b)(1) , no penalty may be assessed unless the initial determination is personally approved in writing by the immediate supervisor of the individual making the determination .

How do I resolve a GHW investigation?

Resolution pathways include: (1) Fast Track Settlement under I.R.M. 8.26.2 to resolve issues during the examination; (2) IRS Independent Office of Appeals proceedings under I.R.C. § 7801(a)(1) , where the Appeals officer may consider hazards of litigation under I.R.M. 8.11.1.2.7.5(1) ; and (3) U.S. Tax Court litigation under I.R.C. § 6213(a) if administrative resolution fails. The taxpayer bears the burden of proof under Tax Court Rule 142(a) , though it may shift under I.R.C. § 7491(a) if the taxpayer introduces credible evidence.

Conclusion

Resolving GHW investigations requires mastery of the examination authority hierarchy from I.R.C. § 7602 through Treas. Reg. § 301.7602-1 , United States v. Clarke, 573 U.S. 248 (2014), and I.R.M. 4.52.1 . For ultra-high-net-worth individuals, the GHW Program represents a sophisticated, enterprise-wide examination that evaluates the entire financial ecosystem of the taxpayer, including trusts, partnerships, S corporations, and private foundations .

The critical steps for UHNWIs are: (1) prepare documentation across all enterprise entities before the examination begins; (2) manage IDRs using the procedures in I.R.M. 4.52.1.5.2; (3) challenge penalties on procedural grounds under I.R.C. § 6751(b)(1) ; (4) use Fast Track Settlement under I.R.M. 8.26.2 to resolve issues early; and (5) preserve appeal rights through the IRS Independent Office of Appeals under I.R.C. § 7801(a)(1) .

The limitations of this analysis are inherent in any general treatment: circuit-specific interpretations, evolving IRS guidance, and fact-intensive determinations may alter outcomes. Practitioners must verify all citations and apply the law to their specific circumstances.

THIS ARTICLE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE LEGAL ADVICE. THE INFORMATION MAY BE OUTDATED AND YOU ARE NOT TO RELY ON IT. CONTACT YOUR PROFESSIONAL TO GUIDE YOU BASED ON YOUR CURRENT SITUATION, OR WHAT MAY APPLY TO PREVIOUS YEARS. THIS ARTICLE IS ONLY MEANT TO PROVIDE GENERAL INFORMATION AND NOT A SPECIFIC ANSWER. YOU ARE NOT OUR CLIENT AND WE HAVE NOT ADVISED YOU.

Author Bio

Alan Goldstein is an Enrolled Agent and researcher with 26 years of experience in federal and state tax controversy. He advises high-net-worth families and closely held businesses on income-shifting strategies, charitable planning, and IRS audit defense.

Last Updated: October 2026

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          "acceptedAnswer": {
            "@type": "Answer",
            "text": "Under the IRS's Strategic Operating Plan, audit rates for individuals with incomes over $10 million are projected to reach 16.5% by 2026, up from 11% in 2019. For large complex partnerships, audit rates are projected to increase from 0.1% to 1% by 2026. The GHW Program uses advanced analytics and artificial intelligence to identify high-risk returns."
          }
        },
        {
          "@type": "Question",
          "name": "Can I challenge a GHW summons issued to a third party?",
          "acceptedAnswer": {
            "@type": "Answer",
            "text": "Yes, but the standard is demanding. Under United States v. Clarke, 573 U.S. 248 (2014), a taxpayer has the right to examine IRS officials regarding their reasons for issuing a summons only if the taxpayer points to specific facts or circumstances plausibly raising an inference of bad faith. A bare allegation of improper purpose is insufficient. The taxpayer must also satisfy the United States v. Powell, 379 U.S. 48 (1964), requirements for challenging summons enforcement."
          }
        },
        {
          "@type": "Question",
          "name": "What penalties can the GHW Program impose?",
          "acceptedAnswer": {
            "@type": "Answer",
            "text": "The GHW Program can impose the 20% accuracy-related penalty under I.R.C. § 6662(a), increased to 40% for gross valuation misstatements under I.R.C. § 6662(h) or undisclosed foreign assets under I.R.C. § 6662(i). The 75% fraud penalty under I.R.C. § 6663 applies to fraudulent underpayments. Under I.R.C. § 6751(b)(1), no penalty may be assessed unless the initial determination is personally approved in writing by the immediate supervisor of the individual making the determination."
          }
        },
        {
          "@type": "Question",
          "name": "How do I resolve a GHW investigation?",
          "acceptedAnswer": {
            "@type": "Answer",
            "text": "Resolution pathways include: (1) Fast Track Settlement under I.R.M. 8.26.2 to resolve issues during the examination; (2) IRS Independent Office of Appeals proceedings under I.R.C. § 7801(a)(1), where the Appeals officer may consider hazards of litigation under I.R.M. 8.11.1.2.7.5(1); and (3) U.S. Tax Court litigation under I.R.C. § 6213(a) if administrative resolution fails. The taxpayer bears the burden of proof under Tax Court Rule 142(a), though it may shift under I.R.C. § 7491(a) if the taxpayer introduces credible evidence."
          }
        }
      ]
    }
  ]
}

Author: agoldstein