On Aug. 16, 2022, President Joe Biden signed the Inflation Reduction Act (IRA) into law, which allocated more than $40 billion to the Internal Revenue Service (IRS) for tax enforcement activities over a span of 10 years. Although this funding did and continues to fill important IRS needs for tax enforcement resources, it comes with the expectation that the allocated money will be used in a manner likely to result in significant future tax collections.

Since the IRS began receiving this funding, the IRS commissioner has announced several new initiatives and existing areas of increased scrutiny focused on extracting additional taxes and penalties from wealthy Americans. This includes audits of corporate jet usage, high-income nonfiler initiatives and civil examinations/criminal investigations into alleged tax avoidance transactions involving micro-captives, syndicated conservation easements, Puerto Rico Act 20/22/60 incentives, and Malta pension plans.