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Navigating IRS Corporate and High-Income Taxpayer Audits: Key Areas of Focus for Examinations, Pitfalls to Avoid

High-Income Collections, Partnership Audit Strategy, Digital Assets, Offshore Structures, Syndicated Conservation Easements

Recording of a 90-minute premium CLE/CPE video webinar with Q&A

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Conducted on Thursday, February 1, 2024

Recorded event now available

or call 1-800-926-7926

This CLE/CPE webinar will review the IRS' latest campaign targeting high-income taxpayers, partnerships, corporations, and promoters. The panel will discuss the state of the current initiative, explain how to handle the IRS examination itself, voluntary disclosure options, current challenges facing taxpayers, and tactics to avoid penalties. The panel will also discuss key areas of focus where the IRS has detected abuse, such as digital assets, offshore structures, micro-captive insurance arrangements, syndicated conservation easements, and more.


The IRS has rolled out its plan for increased examinations and collection efforts specifically focused on high-income taxpayers, partnerships, and promoters. In addition, other enforcement initiatives will focus on compliance issues involving digital assets, reporting of offshore accounts, the use of offshore structures, and collection of back taxes owed by certain individual taxpayers.

The increase in funding under the Inflation Reduction Act has allowed the IRS to tap into the use of artificial intelligence and other new technologies to detect tax evasion, identify compliance threats, and improve case selection. This will certainly result in a high number of audit letters, civil and criminal investigations, and enforced compliance for some high net worth individuals and companies.

Tax professionals must identify critical issues for taxpayers who may be subject to IRS examination and implement strategies for managing these audits and minimize potential tax liability and penalties.

Listen as our panel discusses recent IRS enforcement actions, current challenges facing taxpayers, tactics to avoid penalties, and key areas of focus where the IRS has detected abuse, as well as offer concrete suggestions on managing IRS examinations and collection efforts, taxpayer rights, and other critical items.



  1. Recent IRS enforcement and collection initiatives
  2. IRS areas of focus under the current enforcement initiative
    1. Digital assets
    2. Offshore structures
    3. Micro-captive insurance arrangements
    4. Syndicated conservation easements
  3. Abusive tax avoidance transactions
  4. Compliance procedures to minimize chances of an audit
  5. Navigating audit procedures and pitfalls to avoid


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, partnerships, and promoters?
  • How do you navigate the use of offshore structures, micro-captive insurance arrangements, and other tax planning options?
  • 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


Stein, Michel
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

Stigile, Cory
Cory Stigile

Hochman Salkin Toscher Perez

Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation...  |  Read More

Toscher, Steven
Steven (Steve) Toscher

Managing Principal
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

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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