New IRS Office of Promoter Investigations: Avoiding and Preparing for Examinations
Conservation Easements, Micro-Captive Insurance, and Other Abusive Schemes
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will discuss the IRS' newly created Office of Promoter Investigation established to combat abusive tax avoidance transactions. Our panel of tax litigators will prepare tax professionals and taxpayers for these audits and offer steps that taxpayers can take to mitigate chances of selection.
Outline
- Background
- IRS structure
- Targeted transactions
- Conservation easements
- Micro-captive insurance
- Other transactions
- Handling the examination
- Criminal investigations
- Proactive steps to avoid selection
Benefits
The panel will review these and other critical issues:
- Which conservation easement transactions are being targeted?
- When should a taxpayer be concerned that they may be referred to Criminal Investigations?
- What penalties could be charged for participating in tax avoidance transactions?
- How should practitioners prepare for these upcoming examinations?
Faculty
Evan J. Davis
Principal
Hochman Salkin Toscher Perez
Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive... | Read More
Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive civil and criminal trial and appellate experience in both federal and state courts. He and his cases have been profiled by the New York Times, Wall Street Journal, Los Angeles Times, People Magazine, as well as national legal publications such as Tax Notes and Law360. Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, civil tax controversy and litigation, sensitive-issue or complex civil tax examinations and administrative tax appeals, and federal and state white-collar criminal investigations. He represents numerous cryptocurrency clients worldwide on civil and criminal tax matters, speaks frequently on cryptocurrency, criminal tax, and Bank Secrecy Act issues, deals with civil and criminal cannabis-related tax issues, and handles civil and criminal unreported foreign account and foreign-entities investigations and disclosures. In the appellate arena, Mr. Davis has argued cases before the Ninth Circuit Court of Appeals as both a prosecutor and defense counsel and was trial and appellate counsel on the attorney-client privilege case In re Grand Jury, which the U.S. Supreme Court heard in 2023. Mr. Davis frequently lectures on many topics throughout the country both in the private sector and as a federal prosecutor.
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Dennis L. Perez
Principal
Hochman Salkin Toscher Perez
Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax... | Read More
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.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 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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