2023 IRS Enforcement Update: Key Areas of Focus for Examinations, Audits, and Criminal Cases

Abusive Tax Avoidance Transactions, Crypto-Related Audits, Criminal Digital Asset Cases, Transfer Pricing, High-Income Taxpayers

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

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Tuesday, February 21, 2023

1:00pm-2:30pm EST, 10:00am-11:30am PST

or call 1-800-926-7926

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.

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.

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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

Faculty

Gavioli, Laura
Laura L. Gavioli

Partner
Alston & Bird

Ms. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an...  |  Read More

Lee, Matthew
Matthew D. Lee

Partner
Fox Rothschild

Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white...  |  Read More

Nemeth, Eric
Eric M. Nemeth

Partner
Varnum

Mr. Nemeth is a partner and leads the firm’s Tax Planning, Compliance and Litigation Practice Team. He has...  |  Read More

Attend on February 21

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Cannot Attend February 21?

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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