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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Wednesday, May 15, 2024

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$197.00
CPE
ALL

This course will review the IRS' latest campaign targeting upper-income taxpayers associated with flow-through entities and private foundations. Our audit experts will discuss the state of the current initiative and explain how to handle the IRS examination itself.

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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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.

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Description

The IRS Large Business and International Division is auditing high net worth individuals and their related entities, including partnerships, S corporations, trusts, and private foundations. The Wealth Squad, a highly-trained division of the IRS, is conducting these audits.

These examinations will target recently enacted and complex areas of taxation, including:

  • Section 199A Qualified Business Income Deduction
  • Section 163(j) Business Interest Deduction Limitation
  • Section 965 Repatriation of Previously Untaxed Foreign Earnings
  • Section 172 Net Operating Loss Deduction Refund Claims
  • Required foreign reporting of trusts, bank accounts, assets, etc.

Although targeting specific areas, these are comprehensive audits covering most aspects of a taxpayer's tax return. Tax professionals working with high-wealth clients need to prepare for potential examinations and understand how to represent these taxpayers.

Listen as our panel of tax experts provides the latest information on these comprehensive audits, including the IRS selection process, information document requests, supporting documentation, audit adjustments, appeals, and litigation.

Outline

  1. The current IRS initiative
  2. The structure of the IRS
  3. The selection process
  4. Proactive preparation
  5. The examination process
  6. Appeals
  7. Litigation

Benefits

The panel will review these and other critical issues:

  • What is known about the current IRS selection process?
  • Which taxpayers and transactions are being targeted?
  • How can taxpayers best prepare for potential audits?
  • What caveats should tax professionals be wary of when representing taxpayers during high net worth audits?
  • When should a taxpayer go to appeals, and how does the current IRS appeals process work?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Determine the focus and priorities of the IRS "Wealth Squad"
  • Identify the various factors that may lead to the auditing of a high-wealth or high income taxpayer
  • Establish the information and documents to gather for IRS information document requests
  • Ascertain that the taxpayer is fully prepared for high-wealth or high income taxpayer audits
  • Recognize the various IRS operating divisions and how they interact
  • Distinguish current IRS enforcement priorities from areas not currently prioritized

  • 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.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).