The Transactional Records Access Clearinghouse at Syracuse University yesterday released Few Millionaires Audited by IRS Global High Wealth Group:

Despite considerable IRS fanfare in late 2009 and early 2010, a special government effort claiming to target "global high wealth" individuals completed audits on only 36 of these super high income returns in the nearly two and a half years since the program was announced. …

While the overall achievements of various components of the special project are scanty, it is true that the records indicate they have turned up an additional $47,729,198 in taxes that IRS agents said were owed.

Table 1. Global High Wealth Audits of Taxpayers Reporting $1 Million or More

	FY 2011	FY 2012	Cumulative
Additional Taxes Recommended	$20,140,136	$27,589,062	$47,729,198
Total Number of Audits	18	18	36
with change	14	10	24
with no change	4	8	12
percent no change	22%	44%	33%

However, Table 1 further shows that the agency closed a remarkably large proportion of these GHW examinations as "no change" audits. A "no change" audit is one where the auditors have determined that no additional taxes were owed. For the full twenty-nine months since this new unit was set up, the agency said that in fully one-third of these high-end audits no additional taxes were warranted. And, looking at a more recent period — the first five months of FY 2012 — the "no change" rate was somewhat higher, with 44 percent of such audits being given a pass.

While returns without problems might be expected to close more quickly, considering the complicated tax affairs of global high wealth individuals, the fact that IRS found no issues in the reporting of their tax affairs seems remarkable.

Whether judged by the limited number of audits of "global high wealth individuals" or by the limited resources assigned, this program has not lived up to the fanfare with which it was announced. The IRS Commissioner may need to speak with less hype and more honesty about the sufficiency of agency resources to ensure that high wealth individuals are receiving adequate audit attention. Clearly the program has not yet achieved what the Commissioner promised when it was created: the delivery of a "game-changing strategy" for the IRS that will give the agency "a unified look at the entire complex web of business entities controlled by a high wealth individual."

• IRS, FY 2012 Enforcement and Service Results
• Treasury Inspector General for tax Administration, Fiscal Year 2012 Annual Audit Plan
• Bloomberg, IRS Conducted 36 High-Wealth Program Audits, Report Says
• CNN, Audits of Super-Duper Rich Off to a Slow Start
• Huffington Post, IRS Audits Of Super Rich Still Few And Far Between, Report Finds
• Reuters, IRS Tax Auditing Lags for Ultra-Wealthy: Report