Estate and Gift Tax Audits: Transfers, Valuation of Assets, Formula Clauses, GRATs, Forms 3520 and 3520-A, Penalties
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will provide trust and estate attorneys with an in-depth analysis of the processes and strategies for handling estate and gift tax audits, recent case law, and IRS developments. The panel will discuss key IRS audit triggers, issues stemming from hard to value asset transfers, formula clauses, and preparing tax returns. The panel will also discuss challenges GRATs and Forms 3520 and 3520-A, as well as offer strategies for avoiding penalties.
Outline
- Issues to expect
- Avoiding audit triggers
- Protecting the burden of proof
- Extending the statute
- The appeals process
- The current state of the IRS initiative
Benefits
The panel will discuss these and other key issues:
- What are the hot issues that trigger estate and gift tax audits?
- Complying with the all-important adequate disclosure requirements with gift tax returns
- What are the most common estate and gift tax audit triggers?
- How to lessen the chances of being selected for a gift or estate return audit
- What are the timelines, processes, and deadlines involved in an estate and gift tax audit?
- When to permit the extension of the statute of limitations with gift tax audits
- What challenges arise from the use of GRATs and other planning techniques?
- How to complete Forms 3520 and 3520-A
- How to best communicate with the IRS
Faculty
Benjamin A. Cohen-Kurzrock
Senior Associate
Baker Botts
Mr. Cohen-Kurzrock is a tax attorney who works with the firm's Private Client Services team to represent the... | Read More
Mr. Cohen-Kurzrock is a tax attorney who works with the firm's Private Client Services team to represent the Nation's wealthiest individuals and families on the design, implementation, and defense of their estate and business succession plans. As part of that team, his practice focuses on fiduciary and tax controversy and litigation matters, with the goal of preserving wealth with or without a trial.
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Lawrence M. Lipoff, CPA, TEP, CEBS
Director
CohnReznick
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private... | Read More
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high net worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely-held businesses in the areas of income tax planning and compliance, estate planning and administration services, consultation regarding formation of family trusts and philanthropic structures. He is a frequent lecturer and author of articles published through professional forums on topics that include preparation of 1040/1041 & 706/709 returns, IRA/pension distribution, domestic and international asset protection, business succession, generation-skipping transfers, S corporation and fiduciary taxation including foreign trusts, alternative minimum tax, Chapter 14, family limited partnerships, international estate planning and administration, grantor charitable lead trusts, captive insurance companies, private placement life insurance and carried interest estate planning for private equity and hedge fund principals.
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