Officials from the United States’ Internal Revenue Service (IRS) have indicated that the agency is analysing the use of private foundations for tax planning, transatlantic law firm McDermott Will & Emery has warned.

Tamera Ripperda, who is the commissioner of the IRS’s tax exempt and government entities (TEGE) division and previously served as the industry director for the global high wealth in the large business and international (LB&I) division at the IRS, said the agency is focusing on cross-division collaborations to target high-income, high-wealth taxpayers.

The TEGE division has trained more than 400 L...