IRS Scrutiny of Trusts: Abusive Trust Arrangements
Preparing for and Handling IRS Trust Examinations

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Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Wednesday, May 22, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
-
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).
This webinar will review the current state of IRS challenges to trusts. Our panel of trust and estate advisers will discuss trust structures, targeted abusive tax schemes, recent cases and rulings, and how to prepare for and handle an IRS audit of a trust.
Faculty

Mr. Capdevielle Capdevielle is a highly experienced probate, trust, and tax attorney with more than 30 years of success representing trustees, beneficiaries, fiduciaries, and high-net-worth individuals in complex tax, estate, and trust, matters. Licensed in Nevada, California, and Texas, Cliff brings a unique cross-jurisdictional perspective to high-stakes disputes and sensitive family matters involving wealth transfer, inheritance, and fiduciary obligations. Before joining Saltzman Mugan Dushoff LLP, he served as Managing Attorney at Moskowitz LLP, a nationally recognized tax law firm, where he oversaw high dollar tax controversy matters. Earlier in his career, Mr. Capdevielle worked in the Tax Department at Deloitte, gaining deep experience at the intersection of tax law, finance, and business planning—expertise that now powers his sophisticated approach to estate, trust, and tax matters.

Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Mr. Roberts brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships and corporations.
Description
The IRS has increased its scrutiny of wealthy taxpayers. Since trusts are significant wealth transferring, tax-saving, and privacy vehicles, this has precipitated an intense focus on trusts by the IRS. Unfortunately, unscrupulous promoters have historically marketed trust arrangements that evade federal income tax, often charging hefty fees.
The IRS maintains a website designated to these abusive tax evasion schemes. The site details basic trust taxation rules, abusive domestic and foreign trust schemes, and other pertinent information, including a list of relative laws and arguments. Among these are landmark cases like Gregory v. Helvering and Lucas v. Earl. Trust and estate advisers should be familiar with the nuances of these cases, their application to trusts, and recent court decisions relative to trust arrangements.
Listen as our panel of fiduciary tax experts explains how to review current trust structures and prepare for IRS examinations of trusts.
Outline
- Trust basics
- Types of trusts
- Targeted abusive tax schemes
- Recent cases and rulings
- Handling an IRS trust examination
- Properly reviewing and structuring trusts
- Best practices
Benefits
The panel will cover these and other critical issues:
- How to prepare for IRS examinations of trust arrangements
- What abusive tax schemes are being targeted by the IRS
- The impact of recent and landmark cases on trusts
- Trust taxation and types of trusts
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Identify basic types of trusts
- Determine how recent cases impact trust arrangements
- Decide how to best handle an IRS examination of a trust
- Ascertain key differences between proper and abusive trusts
- 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 estate, gift and trust taxation including various trusts types, the unified credit, and portability.

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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