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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, March 9, 2023

  • schedule Time

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

  • timer Program Length

    90 minutes

Credit Information

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

  • 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).

$347.00

This CLE/CPE webinar will provide guidance to tax professionals on the 2023 IRS enforcement initiatives and key issues for taxpayers. The panel will discuss recent IRS investigations, abusive tax avoidance transactions, increased crypto-related audits, criminal digital asset cases, transfer pricing, and examinations of high-income taxpayers. The panel will also offer tactics for navigating the processes involved for examinations, penalties, and criminal cases.

Faculty

Laura L. Gavioli
Miscellaneous

Ms. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, she is known for achieving practical, client-driven goals when defending against IRS inquiries. Ms. Gavioli has represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the U.S. and advises clients on the IRS Whistleblower Program. She attained taxpayer victories in civil tax cases in U.S. Tax Court and federal district courts, eliminating IRS penalties.

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Matthew D. Lee
Partner
Fox Rothschild LLP

Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense, federal tax controversies, financial institution regulatory compliance, and complex civil litigation. He has significant experience in conducting corporate internal investigations and advising banks and financial institutions as to compliance issues involving FATCA, the Bank Secrecy Act, the USA Patriot Act, anti-money laundering laws and regulations, and economic sanctions. He also represents financial institutions in enforcement proceedings brought by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN).

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Eric M. Nemeth
Partner
Varnum LLP

Mr. Nemeth is a partner and leads the firm’s Tax Planning, Compliance and Litigation Practice Team. He has extensive experience in tax law with a focus on all aspects of related civil and criminal law, as well as complex financial investigative and litigation matters.

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Description

Tax enforcement has been down over the past couple of years, but is expected to have a substantial increase throughout 2023 due to increased funding from the Inflation Reduction Act of 2022. Tax professionals must grasp a complete understanding of recent IRS enforcement initiatives and plan accordingly for impacted taxpayers.

Recent IRS enforcement actions and tax disputes have involved (1) increases in the examination of high-income taxpayers; (2) the use of the economic substance doctrine in transfer pricing examinations; (3) crypto-focused audits and criminal cases; and (4) a crackdown on abusive transactions.

In addition, more examinations and tax disputes are expected due to proposed restrictions on access to IRS appeals for certain matters. Taxpayers and tax advisers must be prepared to handle increased IRS scrutiny and plan accordingly for transactions and reporting to better defend against the impending wave of tax enforcement.

Listen as our panel discusses recent IRS investigations and tax cases, abusive tax avoidance transactions, crypto-related audits, criminal digital asset cases, transfer pricing, and examinations of high-income taxpayers. The panel will also offer tactics for navigating the processes involved for examinations, penalties, and criminal cases.

Outline

  1. High-income taxpayers
  2. Transfer pricing examinations
  3. Crypto and other digital asset transactions
  4. Abusive tax avoidance transactions
  5. Other IRS areas of focus and key considerations for taxpayers

Benefits

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?
  • What is the IRS' current outlook and treatment of crypto transactions and reporting?
  • 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

NASBA Details

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 at mid-level within the organization, preparing complex tax forms and schedules for domestic and multinational businesses; supervisory authority over other preparers/accountants. Knowledge and understanding of information filing requirements and penalties for non-compliance; familiarity with IRS processes for penalty abatement requests and civil fraud cases.

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).