Navigating IRS Corporate and High-Income Taxpayer Audits: Key Areas of Focus for Examinations, Pitfalls to Avoid
High-Income Collections, Partnership Audit Strategy, Digital Assets, Offshore Structures, Syndicated Conservation Easements
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Thursday, February 1, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This CLE/CPE webinar will review the IRS' latest campaign targeting high-income taxpayers, partnerships, corporations, and promoters. The panel will discuss the state of the current initiative, explain how to handle the IRS examination itself, voluntary disclosure options, current challenges facing taxpayers, and tactics to avoid penalties. The panel will also discuss key areas of focus where the IRS has detected abuse, such as digital assets, offshore structures, micro-captive insurance arrangements, syndicated conservation easements, and more.
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.
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.
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). Mr. Stigile frequently writes and lectures on topics involving taxation.
The IRS has rolled out its plan for increased examinations and collection efforts specifically focused on high-income taxpayers, partnerships, and promoters. In addition, other enforcement initiatives will focus on compliance issues involving digital assets, reporting of offshore accounts, the use of offshore structures, and collection of back taxes owed by certain individual taxpayers.
The increase in funding under the Inflation Reduction Act has allowed the IRS to tap into the use of artificial intelligence and other new technologies to detect tax evasion, identify compliance threats, and improve case selection. This will certainly result in a high number of audit letters, civil and criminal investigations, and enforced compliance for some high net worth individuals and companies.
Tax professionals must identify critical issues for taxpayers who may be subject to IRS examination and implement strategies for managing these audits and minimize potential tax liability and penalties.
Listen as our panel discusses recent IRS enforcement actions, current challenges facing taxpayers, tactics to avoid penalties, and key areas of focus where the IRS has detected abuse, as well as offer concrete suggestions on managing IRS examinations and collection efforts, taxpayer rights, and other critical items.
- Recent IRS enforcement and collection initiatives
- IRS areas of focus under the current enforcement initiative
- Digital assets
- Offshore structures
- Micro-captive insurance arrangements
- Syndicated conservation easements
- Abusive tax avoidance transactions
- Compliance procedures to minimize chances of an audit
- Navigating audit procedures and pitfalls to avoid
The panel will discuss these and other key issues:
- What have been the key areas of focus in recent IRS investigations and tax disputes?
- What tax reporting and compliance issues arise for high-income taxpayers, partnerships, and promoters?
- How do you navigate the use of offshore structures, micro-captive insurance arrangements, and other tax planning options?
- What transactions have the IRS considered to be abusive tax avoidance transactions?
- How to navigate IRS investigations and avoid or limit penalties or criminal liability
Learning Objectives
After completing this course, you will be able to:
- Identify key areas of focus in recent IRS investigations and tax disputes
- Recognize the tax reporting and compliance issues that arise for high-income taxpayers
- Ascertain the IRS' current outlook and tax treatment of crypto transactions
- Identify what transactions the IRS considers to be abusive tax avoidance transactions
- Understand how to navigate IRS investigations and avoid or limit penalties or criminal liability
- 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 pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests; knowledge and understanding ofIRS audit 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.
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
