The IRS Global High Wealth Industry (“GHWI”) (part of the IRS Large Business & International Division) is auditing individuals with tens of millions of assets or income who utilize complicated financial and estate plan structures.  GHWI was established by the IRS in late 2009, but now has a few years of service “under its belt”.  The GHWI audit process involves a review of not only the taxpayer’s personal income tax return, but can expand to include a review of a taxpayer’s related partnership tax returns, fiduciary income tax returns, and estate and gift tax returns, to name a few.  As part of the audit process, GHWI will analyze the taxpayer’s complete financial picture, and the enterprises that the taxpayer controls (including partnerships, trusts, subchapter S corporations, C corporations, private foundations, etc.).  The audit can expand to include a review of the taxpayer’s returns for multiple years, and even the tax returns of individuals related to the taxpayer.  This scope of audit is in contrast to the IRS historical approach of focusing on a single type of tax return, for a single taxpayer, for a single year.  GHWI audit teams are supported by IRS counsel throughout the audit process due to the complexity of the issues that are the subject of the audits.  A taxpayer will know when he or she is under audit by GHWI because the IRS examiner will identify himself or herself as part of such group.