High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance
A live 90-minute premium CLE/CPE webinar with interactive Q&A
This CLE/CPE webinar will provide counsel and tax advisers with guidance on available options for handling high income non-filers and navigating IRS collection issues. The panel will discuss recent IRS enforcement actions for high income taxpayers, voluntary disclosure options, current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.
- Recent IR-2020-34 and challenges for high income non-filers
- IRS enforced collection process
- Voluntary disclosure
- Collection alternatives
- Criminal prosecution
The panel will review these and other key issues:
- What are the key challenges in representing high income non-filers?
- What are the IRS penalty structures and pitfalls to avoid as applied to high income non-filers?
- What is the correspondence chain leading up to enforced collection action by the IRS?
- What are the remedies and relief provisions to challenge or mitigate a tax lien?
Michel R. Stein
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.Close
Steven (Steve) Toscher
Hochman Salkin Toscher Perez
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions... | Read More
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.Close
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