BarbriSFCourseDetails
  • videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Navigating IRS Corporate and High-Income Taxpayer Audits

High-Income Collections, Partnership Audit Strategy, Digital Assets, Offshore Structures, Syndicated Conservation Easements

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About the Course

Introduction

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.

Description

The IRS has 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 offers concrete suggestions on managing IRS examinations and collection efforts, taxpayer rights, and other critical items.

Presented By

Timothy Bilotta
Senior Executive Tax Strategist and Compliance Expert
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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. 

Cory Stigile
Principal
Hochman Salkin Toscher Perez, PC

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.

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


  • Live Online


    On Demand

Date + Time

  • event

    Wednesday, March 4, 2026

  • schedule

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

I. Recent IRS enforcement and collection initiatives

II. IRS areas of focus under the current enforcement initiative

A. Digital assets

B. Offshore structures

C. Micro-captive insurance arrangements

D. Syndicated conservation easements

III. Abusive tax avoidance transactions

IV. Compliance procedures to minimize chances of an audit

V. 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 has the IRS considered to be abusive tax avoidance transactions?
  • How to navigate IRS investigations and avoid or limit penalties or criminal liability