Interested in training for your team? Click here to learn more

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 program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, August 26, 2021

Recorded event now available

or call 1-800-926-7926

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.


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.



  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


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?


Davis, Evan
Evan J. Davis

Hochman Salkin Toscher Perez

Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive...  |  Read More

Perez, Dennis
Dennis L. Perez

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

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

Access Anytime, Anywhere

CPE credit is not available on downloads.