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Federal Tax Controversy: IRS Enforcement Trends and Developments


Level: Intermediate
Runtime: 57 minutes
Recorded Date: February 28, 2023
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Agenda

  • Recent IRS Budgetary Issues
  • Remote Trial Procedures in the Tax Court
  • IRS Office of Promoter Investigations, Office of Fraud Enforcement and Civil Fraud Penalty Development
  • Recent Conservation Easement Developments
  • Joint Chiefs of Global Tax Enforcement: What is it and how it impacts Taxpayers?
  • Cyber Crimes and Virtual Currency Enforcement
  • Return Preparer Fraud
  • Employment Tax Fraud

Runtime: 57 minutes
Recorded: February 28, 2023

For NY - Difficulty Level: For both newly admitted & experienced attorneys

For NY - Difficulty Level: Both newly admitted and experienced attorneys

Description

The COVID-19 pandemic has brought sharp changes to the tax enforcement priorities of the Internal Revenue Service (IRS), specifically in implementing its remote audits. Recently, the IRS and the Treasury Department released proposed treasury regulations related to the electronic filing of certain tax returns and statements. These, along with other significant developments, have been the result of the Biden administration’s efforts to address recent tax compliance issues and controversies.
The increased IRS enforcement underscores the continuous demand to invest in information technology capabilities to better cope with the emerging challenges. Additionally, financial institutions need to ensure that existing tax procedures are aligned with the latest tax litigation developments.
Our panel of key thought leaders and practitioners will offer a discussion of the latest and significant issues surrounding federal tax controversy as well as the IRS enforcement trends and developments. This LIVE Webcast aims to help you avoid potential tax compliance risks and disputes.

Key issues that will be covered in this course are:
  • Emerging Tax Compliance Issues
  • IRS Tax Enforcement Trends and Challenges
  • Strategies to Avoid Tax Compliance Disputes
  • Latest Developments in Tax Litigation
  • What Lies ahead

Learning Objectives:
  • Determine the latest updates and significant issues surrounding federal tax controversy, such as on conservation easements.
  • Identify the criminal tax enforcement priorities of the IRS including cybercrimes, cryptocurrency enforcement, return preparer fraud, and employment tax Fraud.

This program was recorded on February 28th, 2023.

Provided By

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Panelists

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Eric M. Nemeth

Partner
Varnum LLP

Eric 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.
Through a collaborative and proactive process, he has achieved exceptional results, including multiple discontinued or “dropped” investigations, litigation victories and, where appropriate, effective sentencing advocacy resulting in multiple occasions of greatly reduced sentences or no jail time for his clients.
The ability to organize and plan a highly technical or complex defense to an investigation also enables Eric to conduct proactive fraud investigations on behalf of clients that suspect embezzlement or theft by employees or contractors.

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W. Curtis Elliott, Jr.

Partner
Culp Elliott & Carpenter PLLC

Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott’s clients include Fortune 500 companies, entrepreneurial companies, estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics.


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