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

A live 110-minute CPE webinar with interactive Q&A


Thursday, August 26, 2021

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, July 30, 2021

or call 1-800-926-7926

This webinar 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.

Description

Established in April 2021, the Office of Promoter Investigation intends to detect and deter the activities of promotors profiting from abusive tax avoidance transactions. Conservation easements, micro-captive insurance arrangements, and other tax avoidance transactions will be targeted.

Located within the Small Business/Self-Employed division of the IRS, the Office will coordinate investigations with Large Business & International, Tax Exempt/Government, and other divisions of the IRS, including Criminal Investigations because many of these examinations will have criminal implications. The IRS will likely increase its pursuit of criminal prosecutions, requiring tax practitioners and taxpayers to be ready for these serious inquiries.

Listen as our panel of tax experts explains the role of the new office, specific activities that are being targeted, and how to prepare for these upcoming audits.

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Outline

  1. Background
  2. IRS structure
  3. Targeted transactions
    1. Conservation easements
    2. Micro-captive insurance
    3. Other transactions
  4. Handling the examination
  5. Criminal investigations
  6. 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

Davis, Evan
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

Perez, Dennis
Dennis L. Perez

Principal
Hochman Salkin Toscher Perez

Mr. Perez represents and advises U.S. taxpayers in foreign and domestic voluntary disclosures, sensitive issue civil...  |  Read More

Stein, Michel
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

Attend on August 26

Early Discount (through 07/30/21)

CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.

Cannot Attend August 26?

Early Discount (through 07/30/21)

CPE credit is not available on downloads.

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