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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

    Tuesday, September 14, 2021

  • 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 guide tax professionals through new IRS enforcement actions focused on promoters of syndicated conservation easements and micro-captive arrangements. The panel will discuss recent IRS investigations of promoters of what they determine as abusive tax avoidance transactions, navigating the processes involved for examinations, new procedures of the IRS Office of Promoter Investigation, penalties, and key strategies for tax professionals. The panel will also discuss structuring micro-captives and conservation easement transactions to minimize IRS assessments and audits.

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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Sandra R. Brown
Principal
Hochman Salkin Toscher Perez, PC

Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.

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Lois E. Deitrich
Acting Director, Office of Promoter Investigations
Internal Revenue Service

Ms. Deitrich has 20 years of experience with the IRS, having begun her career as a revenue officer in 2001. Prior to her current appointment, she was the director of the southwest area of SB/SE, overseeing abusive transaction investigations. Ms. Deitrich has also previously served as director of Exam Case Selection and Exam Quality and Technical Support.

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Description

Recently, the IRS announced the new Office of Promoter Investigations to combat abusive tax avoidance transactions. As the IRS expands its operations and enforcement actions, tax professionals and advisers must prepare to defend targeted taxpayers on syndicated conservation easements and micro-captive insurance arrangements.

Over the past year, the crackdown on conservation easement transactions has forced taxpayers, tax counsel, and advisers to recognize critical tax issues in structuring these transactions. Conservation easements are legally enforceable perpetual land preservation agreements between a landowner and either a government agency or a qualified land protection organization (such as a land trust) to conserve land and its resources. Grantors within these transactions enjoy significant tax benefits if the easement meets IRS approval for a donation.

In addition, the use of captive insurance companies, particularly Section 831(b) "micro-captives," has come under increased IRS scrutiny as well. The IRS has explicitly recognized micro-captives as a legitimate form of risk protection but has expressed concern that these vehicles are being used more as a wealth transfer device than legitimate insurance.

The popularity of conservation easement transactions and micro-captive arrangements makes them prime targets for promoters and investors seeking to take advantage of their tax benefits. However, the IRS may consider these transactions to be abusive tax avoidance schemes based on their structure, leading to potential IRS audits and investigations.

Furthermore, although the IRS has focused investigations on promoters of syndicated conservation easements and micro-captive insurance arrangements, the Service will investigate other transactions that they deem abusive tax avoidance practices.

Listen as our panel discusses recent IRS enforcement actions on promoters, navigating the processes involved in abusive tax avoidance transaction cases, and key tax professionals' strategies.

Outline

  1. IRS Office of Promoter Investigations
  2. Key items of focus for promoter investigations
    1. Syndicated conservation easements
    2. Micro-captive arrangements
    3. Other areas of IRS focus
  3. Avoiding or minimizing examination and penalties
  4. Best practices for tax professionals

Benefits

The panel will review these and other key issues:

  • Overview of new IRS enforcement initiatives aimed at promoters of abusive tax avoidance transactions
  • Key considerations and issues for fund managers and advisers
  • Applicable rules and strategies to avoid IRS scrutiny for syndicated conservation easements
  • Rules and planning to avoid IRS scrutiny for micro-captive arrangements
  • Managing tax audits and collection cases
  • Avoiding or minimizing penalties

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize key areas of focus of the new IRS Office of Promoter Investigations
  • Identify key items targeted by the IRS for promoters of conservation easements and micro-captive arrangements
  • Understand methods to manage IRS investigations effectively
  • Ascertain how penalties are assessed

  • 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 at mid-level within the organization, preparing complex tax forms and schedules for domestic and multinational businesses; supervisory authority over other preparers/accountants. Knowledge and understanding of information filing requirements and penalties for non-compliance; familiarity with IRS processes for penalty abatement requests and civil fraud cases.

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).