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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Tuesday, December 17, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00
CLE
CPE
ALL

This CLE/CPE course will provide trust and estate attorneys with an in-depth analysis of the processes and strategies for handling estate and gift tax audits, recent case law, and IRS developments. The panel will discuss key IRS audit triggers, issues stemming from hard to value asset transfers, formula clauses, and preparing tax returns. The panel will also discuss challenges with GRATs and Forms 3520 and 3520-A and offer strategies for avoiding penalties.

Faculty

Benjamin A. Cohen-Kurzrock
Attorney
Willkie Farr & Gallagher, LLP

Mr. Cohen-Kurzrock is a corporate and securities associate in the San Diego office.

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Lawrence M. Lipoff
Director
CohnReznick LLP

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.

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Description

The IRS has ramped up audits for estate and gift tax returns at a higher rate than income tax returns. IRS audits of estate tax and gift tax returns and audits relating to the failure to file such returns often involve complex legal and factual issues.

When an estate or gift tax return is chosen for an IRS examination and audit, it is a time-consuming and costly process. Trust and estate counsel representing clients faced with an estate or gift tax audit must understand what the IRS is looking for, how a return is selected for audit, what documentation is needed, necessary procedural requirements and available options, and what to expect as part of a settlement. Understanding these steps is essential to successfully concluding an audit.

In addition, attorneys must recognize potential audit risks associated with specific estate planning strategies and related issues, such as transfers of hard to value assets, formula clauses, and the use of GRATs, Forms 3520 and 3520-A, and other items.

Listen as our panel discusses key IRS audit triggers, issues stemming from transfers of hard to value assets, formula clauses, and preparing tax returns. The panel will also discuss the challenges of GRATs and Forms 3520 and 3520-A and offer strategies for defending against audits and avoiding penalties.

Outline

  1. Issues to expect
  2. Avoiding audit triggers
  3. Protecting the burden of proof
  4. Extending the statute
  5. The appeals process
  6. The current state of the IRS initiative

Benefits

The panel will discuss these and other key issues:

  • What are the hot issues that trigger estate and gift tax audits?
  • Complying with the all-important adequate disclosure requirements with gift tax returns
  • What are the most common estate and gift tax audit triggers?
  • How to lessen the chances of being selected for a gift or estate return audit
  • What are the timelines, processes, and deadlines involved in an estate and gift tax audit?
  • When to permit the extension of the statute of limitations with gift tax audits
  • What challenges arise from the use of GRATs and other planning techniques?
  • How to complete Forms 3520 and 3520-A
  • How to best communicate with the IRS

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify the hot issues that trigger estate and gift tax audits
  • Understand how to comply with the adequate disclosure requirements with gift tax returns
  • Ascertain methods to lessen the chances of being selected for a gift or estate return audit
  • Identify the timelines, processes, and deadlines involved in an estate and gift tax audit
  • Understand how to complete Forms 3520 and 3520-A

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of estate and gift taxation and reporting, pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).