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IRS Scrutiny of Trusts: Abusive Trust Arrangements

Preparing for and Handling IRS Trust Examinations

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, May 22, 2024

Recorded event now available

or call 1-800-926-7926

This webinar will review the current state of IRS challenges to trusts. Our panel of trust and estate advisers will discuss trust structures, targeted abusive tax schemes, recent cases and rulings, and how to prepare for and handle an IRS audit of a trust.


The IRS has increased its scrutiny of wealthy taxpayers. Since trusts are significant wealth transferring, tax-saving, and privacy vehicles, this has precipitated an intense focus on trusts by the IRS. Unfortunately, unscrupulous promoters have historically marketed trust arrangements that evade federal income tax, often charging hefty fees.

The IRS maintains a website designated to these abusive tax evasion schemes. The site details basic trust taxation rules, abusive domestic and foreign trust schemes, and other pertinent information, including a list of relative laws and arguments. Among these are landmark cases like Gregory v. Helvering and Lucas v. Earl. Trust and estate advisers should be familiar with the nuances of these cases, their application to trusts, and recent court decisions relative to trust arrangements.

Listen as our panel of fiduciary tax experts explains how to review current trust structures and prepare for IRS examinations of trusts.



  1. Trust basics
  2. Types of trusts
  3. Targeted abusive tax schemes
  4. Recent cases and rulings
  5. Handling an IRS trust examination
  6. Properly reviewing and structuring trusts
  7. Best practices


The panel will cover these and other critical issues:

  • How to prepare for IRS examinations of trust arrangements
  • What abusive tax schemes are being targeted by the IRS
  • The impact of recent and landmark cases on trusts
  • Trust taxation and types of trusts


Capdevielle, Cliff
Cliff A. Capdevielle

Director, Trusts and Estates Tax Services

Mr. Capdevielle helps clients navigate the complex opportunities related to tax planning, business succession planning,...  |  Read More

Roberts, Matthew
Matthew L. Roberts, J.D., LL.M.

Gray Reed

Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients...  |  Read More

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