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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, October 22, 2020

  • 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).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide counsel and tax advisers with guidance on available options for handling high income non-filers and navigating IRS collection issues. The panel will discuss recent IRS enforcement actions for high income taxpayers, voluntary disclosure options, current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.

Faculty

Michel R. Stein
Principal
Hochman Salkin Toscher Perez, PC

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. 

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Steven Toscher
Managing Principal
Hochman Salkin Toscher Perez, PC

Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.

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Dennis L. Perez
Principal
Hochman Salkin Toscher Perez, PC

Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. He was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California.  Mr. Perez is a Certified Tax Specialist, California State Bar Board of Certification and is also a Fellow of the American College of Tax Counsel.  He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. He is a co-author of the BNA Portfolio, Tax Crimes, has served as the Chair of the Los Angeles Lawyer Magazine Editorial Board and is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award for outstanding service to the Los Angeles Lawyer Magazine.  He is past Chair of the Tax Procedure and Litigation Committees of the Taxation Sections of the State Bar of California and the Los Angeles County Bar Association.  Mr. Perez is past President of the Alumni Board for the UCLA School of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation.

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Description

The IRS has increased their focus and efforts on high income taxpayers who haven't filed their tax returns. The potential for significant penalties, limited voluntary disclosure options, and possible criminal prosecution forces tax counsel and advisers to grasp a complete understanding of applicable tax rules and procedures when representing high income taxpayers.

On Feb. 19, 2020, the IRS issued IR-2020-34, which states the IRS "will step up efforts to visit high income taxpayers who in prior years have failed to timely file one or more of their tax returns." The IRS now uses sophisticated data analytics to identify high income non-filers and tax preparers who promote false tax returns, as well as businesses with large amounts of unpaid employment taxes.

Failure to file tax returns can have severe consequences. IRC 6651(a)(1) imposes substantial additions to tax for a failure to file a tax return. Moreover, fraud referrals from the IRS Collection Division have been increasing. There are potential criminal consequences as well: IRC 7203 makes it a misdemeanor to failure to file; if convicted, a taxpayer can be fined up to $25,000 ($100,000 for corporations) in fines and up to one year in prison. Under IRC 7201, a willful failure to file, combined with affirmative acts of evasion, could lead to a potential felony conviction for tax evasion, which can result in up to five years in prison.

Listen as our panel discusses recent IRS enforcement actions for high income taxpayers, IRS voluntary disclosure options, and tactics to avoid penalties and potential criminal prosecution.

Outline

  1. Recent IR-2020-34 and challenges for high income non-filers
  2. IRS enforced collection process
  3. Voluntary disclosure
  4. Collection alternatives
  5. Criminal prosecution

Benefits

The panel will review these and other key issues:

  • What are the key challenges in representing high income non-filers?
  • What are the IRS penalty structures and pitfalls to avoid as applied to high income non-filers?
  • What is the correspondence chain leading up to enforced collection action by the IRS?
  • What are the remedies and relief provisions to challenge or mitigate a tax lien?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the escalation pattern of IRS Notices leading up to enforced collection actions against high income taxpayers
  • Identify IRS voluntary disclosure options for high income non-filers
  • Decide on strategies in responding to IRS Notice of Intent to Levy
  • Discern options for negotiating with IRS during the collection process
  • Identify available challenges to IRS enforcement actions

  • 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, law or public firm experience at mid-level within the organization, handling tax matters for businesses and high net worth individuals; supervisory authority over other attorneys, preparers, accountants. Knowledge and understanding of IRS Enforced Collection Process, including the liens, levies and asset seizures. Familiarity with defending taxpayers in IRS audits, investigations and procedures.

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).