New IRS Office of Promoter Investigations: Avoiding and Preparing for Examinations
Conservation Easements, Micro-Captive Insurance, and Other Abusive Schemes
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' newly created Office of Promoter Investigation established to combat abusive tax avoidance transactions. Our panel of tax litigators will prepare tax professionals and taxpayers for these audits and offer steps that taxpayers can take to mitigate chances of selection.
Outline
- Background
- IRS structure
- Targeted transactions
- Conservation easements
- Micro-captive insurance
- Other transactions
- Handling the examination
- Criminal investigations
- Proactive steps to avoid selection
Benefits
The panel will review these and other critical issues:
- Which conservation easement transactions are being targeted?
- When should a taxpayer be concerned that they may be referred to Criminal Investigations?
- What penalties could be charged for participating in tax avoidance transactions?
- How should practitioners prepare for these upcoming examinations?
Faculty
Evan J. Davis
Principal
Hochman Salkin Toscher Perez
Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, foreign... | Read More
Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, foreign bank reporting, civil tax controversy and litigation, sensitive issue or complex civil tax examinations and administrative tax appeals, and federal and state white-collar criminal investigations including money laundering, Bank Secrecy Act, public corruption, FARA, campaign finance, and health care fraud.
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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 of the California taxing agencies. He also advises clients on a variety of procedural and substantive issues involving California residency. Mr. Perez was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. He is a Certified Tax Specialist, California State Bar Board of Certification. Mr. Perez frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. He has been a lecturer in the USC Marshall School of Business, Leventhal School of Accounting, Masters in Business Tax Program and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation.
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Michel R. Stein
Principal
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.
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