For High-Net-Worth Individuals
High Net Worth Tax Attorney
Key Takeaway
A high-net-worth tax attorney is a lawyer who handles complex tax matters including offshore account compliance (FBAR/FATCA), international tax structuring, estate and gift tax planning, and IRS wealth squad audits. Taxpayers with assets exceeding $10 million face IRS audit rates of 8-12%, significantly higher than the general population. Call Brotman Law at (619) 378-3138 for a free intro call about protecting your wealth from aggressive IRS enforcement.
High Net Worth Means High Tax Exposure.
The IRS dedicates specialized resources to auditing high-income and high-net-worth taxpayers. In 2025, the IRS announced significantly increased audit rates for individuals with income above $1 million — and those numbers continue to climb. If your financial picture includes international investments, offshore accounts, real estate portfolios, or complex business structures, you’re operating in the IRS’s highest-priority enforcement zone.
The penalties for international tax noncompliance are staggering. A single missed FBAR filing can result in penalties of $10,000 per account per year for non-willful violations — or the greater of $100,000 or 50% of the account balance for willful violations. FATCA penalties add another layer. And these penalties are assessed per form, per year, meaning they compound rapidly.
We serve high-net-worth individuals who need both proactive tax planning and, when necessary, aggressive defense against IRS enforcement. Our attorneys handle international tax compliance, voluntary disclosure programs, offshore account remediation, and audit defense for clients with complex financial situations.
Whether you need to get compliant, defend against an audit, or build a tax-efficient structure for your wealth, we bring the specialized expertise these situations demand.
Confidential Consultation
Free 15-minute call. Attorney-client privilege applies from the first conversation.
How We Help High-Net-Worth Clients
Specialized Tax Services for Complex Wealth
International Tax Compliance
FBAR filings, FATCA reporting, foreign trust returns (Forms 3520/3520-A), Form 5471 for foreign corporations, and Form 8865 for foreign partnerships. We ensure full compliance with every international reporting obligation.
Offshore Account Disclosure
If you have unreported foreign accounts, the risk of criminal prosecution is real. We guide clients through voluntary disclosure programs, streamlined filing procedures, and delinquent FBAR submissions to get compliant while minimizing penalties.
FBAR Defense
Facing FBAR penalties or an IRS examination of your foreign accounts? We defend against both willful and non-willful penalty assessments, negotiate reductions, and challenge improper characterizations of your reporting history.
Estate & Gift Tax Planning
Strategic estate planning that minimizes transfer taxes while preserving your wealth for future generations. Grantor trusts, family limited partnerships, charitable structures, and lifetime gifting strategies — all designed to reduce your taxable estate.
Asset Protection
Domestic and international asset protection structures that shield your wealth from creditors, litigation, and excessive tax exposure. We design holding structures, trusts, and entity frameworks that create legally defensible barriers.
IRS Audit Defense
High-income audits are handled by specialized IRS examiners with more experience and more time than standard audits. We represent clients through IRS examinations , appeals, and Tax Court when necessary.
Learn more →Key Risk Areas
Where High-Net-Worth Individuals Face the Greatest Tax Exposure
Unreported Foreign Financial Accounts
The IRS receives foreign account data from over 100 countries through automatic exchange agreements. If you have accounts exceeding $10,000 in aggregate value and haven’t filed FBARs, the IRS likely already knows. Voluntary disclosure before detection is always the better outcome. Read our International Tax Guide for more detail.
Cryptocurrency Holdings
The IRS has made cryptocurrency tax enforcement a top priority. Centralized exchanges report to the IRS, and blockchain analytics tools allow the agency to trace transactions on decentralized platforms. If your crypto portfolio is substantial, proper reporting and tax planning are critical.
California Residency Disputes
California’s top income tax rate of 13.3% makes the state aggressive about claiming residents. If you’ve moved out of California — or split time between California and another state — the FTB may audit your residency. We handle residency disputes and help clients make clean breaks.
Complex Business Exits
Selling a business, taking a company public, or executing a merger creates enormous tax consequences. Exit planning done correctly can save millions in taxes. Done poorly — or not at all — and the tax bill can be devastating. QSBS, installment sales, opportunity zone deferrals, and charitable strategies all require advance planning.
Real Estate Portfolio Tax Exposure
Large real estate portfolios create complex tax situations involving depreciation recapture, 1031 exchanges, passive activity rules, and state nexus issues. We design tax-efficient structures for real estate investors and defend against IRS challenges to exchange transactions and property valuations.
Talk to a Tax Attorney
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Why Brotman Law
The Right Counsel for Complex Wealth
International Tax Depth
We handle FBAR, FATCA, foreign trusts, and cross-border transactions daily — not as a sideline, but as a core practice area.
Absolute Confidentiality
Attorney-client privilege protects every conversation from day one. Your financial situation stays between you and your attorney.
Defense-Informed Planning
Having defended hundreds of audits, we design strategies that withstand IRS scrutiny — because we know exactly what the IRS looks for.
Proactive, Not Reactive
We identify and address tax risks before they become enforcement actions. Annual tax planning reviews keep your strategy current as laws change.
Multi-Disciplinary Approach
Tax law, business law, estate planning, and asset protection — all under one roof. No referrals, no delays, no gaps in strategy.
Discreet & Professional
We understand the sensitivity of high-net-worth tax matters. Our practice is built on discretion, precision, and personalized service.
Frequently Asked Questions
High Net Worth Tax FAQs
What are the penalties for not filing an FBAR? +
Non-willful FBAR penalties can reach $10,000 per account per year. Willful violations carry penalties of the greater of $100,000 or 50% of the account balance — per account, per year. With multiple accounts and multiple years, penalties can exceed the total account value. Criminal prosecution is also possible for willful violations. Early voluntary disclosure dramatically reduces exposure.
I have unreported offshore accounts. What should I do? +
Contact a tax attorney immediately — before doing anything else. Do not file amended returns or delinquent FBARs without legal guidance. Depending on your circumstances, the streamlined filing compliance procedures, delinquent FBAR submission procedures, or a voluntary disclosure may be the best path. Each has different penalty structures and different risk profiles. We assess your situation and recommend the approach that minimizes both penalties and criminal exposure.
How likely am I to be audited as a high-income individual? +
Significantly more likely than average. The IRS has publicly stated that audit rates for taxpayers earning over $1 million will increase substantially, with the goal of reaching audit rates not seen since 2010. International information returns, large deductions, complex entity structures, and cryptocurrency transactions all increase audit probability further.
Can you help me move out of California tax-efficiently? +
Yes. We help high-net-worth individuals establish domicile in other states while minimizing California’s ability to claim continued residency. This involves documenting your departure across multiple factors — driver’s license, voter registration, professional licenses, time tracking, and social ties. Read our California Residency Guide for a detailed overview of the process.
Do I need a tax attorney or a wealth manager? +
You need both, but they serve different roles. Wealth managers handle investment allocation and financial planning. Tax attorneys handle legal structuring, compliance, IRS defense, and strategies that require legal implementation — entity formation, trust creation, voluntary disclosures, and audit representation. We coordinate with your wealth management team to ensure tax strategy and investment strategy are aligned.
What does a high-net-worth tax engagement cost? +
Fees vary based on complexity, but our clients consistently find that the tax savings and penalty avoidance far exceed the cost of representation. For proactive planning engagements, we typically see a 5-10x return on investment in the first year. For defense matters, the comparison is between our fees and the penalties and tax liability we reduce or eliminate. We provide clear fee estimates before any engagement begins.
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Schedule a brief call with our team to discuss your situation. We’ll assess where things stand and outline your options — confidentially and without obligation.
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