High-Income Non-Filers: Handling IRS Examinations, Voluntary Disclosure Program, Criminal Investigations
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' recent campaign to bring high-income non-filers into compliance. Our panel of income tax experts will cover bringing these taxpayers into compliance, minimizing penalties and consequences of noncompliance, and handling the complexities of these IRS examinations.
Outline
- The IRS campaign
- IRS structure
- Non-filer identification process
- Repercussions
- Voluntary disclosure
- IRS examination process
- Appeals, mediation, and litigation
- Best practices
Benefits
The panel will review these and other key issues:
- How the IRS ferrets out high-income non-filers
- Which taxpayers should consider IRS' Voluntary Disclosure program?
- What penalties could be assessed to high-income non-filers and how can they be mitigated?
- Learn when an examination may be referred to the IRS Criminal Investigation Division
Faculty
Sandra R. Brown
Principal
Hochman Salkin Toscher Perez
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations,... | Read More
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.
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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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Cory Stigile
Principal
Hochman Salkin Toscher Perez
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation... | Read More
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). Mr. Stigile frequently writes and lectures on topics involving taxation.
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