High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Wednesday, June 2, 2021
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
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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 course will discuss the IRS' recent campaign to bring high-income non-filers into compliance. Our panel of income tax experts will cover bringing these taxpayers into compliance, minimizing penalties and consequences of noncompliance, and handling the complexities of these IRS examinations.
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.
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.
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.
The IRS issued IR 2020-34 on Feb. 18, 2020, announcing its intent to visit non-filers to bring these taxpayers into compliance. The agency uses data-analytics, whistleblower reports, and even tips from neighbors to track down high-income non-filers.
For these taxpayers, those making more than $100,000 and not filing, failure to respond to initial requests can have major repercussions. These can include referral for criminal investigation, prison time, and of course, substantial penalties. The IRS offers a Voluntary Disclosure Program for domestic taxpayers. Taxpayers willing to admit that they "willfully failed to comply" with tax filing obligations may be able to resolve their noncompliance and minimize repercussions. Advisers working with high-income non-filers need to understand when to consider this alternative.
The examination process is detailed and lengthy. Communicating with the IRS, the information document request, mediation, appeals, and, when warranted, litigation are a few of the examination process stages. Tax advisers handling IRS audits must understand the process and how to best represent the taxpayer.
Listen as our panel of IRS examination experts explains how the IRS identifies high-income non-filers, the IRS Voluntary Disclosure Program and when it can be a sensible solution, and tips for handling the IRS audit from start to finish.
- The IRS campaign
- IRS structure
- Non-filer identification process
- Repercussions
- Voluntary disclosure
- IRS examination process
- Appeals, mediation, and litigation
- Best practices
The panel will review these and other key issues:
- How the IRS ferrets out high-income non-filers
- Which taxpayers should consider IRS' Voluntary Disclosure program?
- What penalties could be assessed to high-income non-filers and how can they be mitigated?
- Learn when an examination may be referred to the IRS Criminal Investigation Division
Learning Objectives
After completing this course, you will be able to:
- Decide when the IRS' Voluntary Disclosure Program would be a practical solution for noncompliant taxpayers
- Identify taxpayers targeted to IRS scrutiny under the high-income non-filer campaign
- Determine when going to appeals may be in the best interest of the taxpayer
- Ascertain when litigation is a viable alternative
- 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 individual income taxation, including itemized deductions, individual income tax credits, net operating loss limitations including carrybacks and carryforwards.
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).
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