Recent IRS Crackdown on Abusive Trust Arrangements: Taxation, Audit Triggers, Reporting, DNI, Foreign Trusts
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide guidance to trusts and estates attorneys and tax professionals on recent IRS enforcement actions and examinations focused on abusive trust arrangements. The panel will discuss key areas of focus by the IRS in examining trust arrangements and related transactions, taxation of trusts and audit triggers, reporting issues and potential civil and criminal penalties, distributable net income (DNI), foreign trust challenges, and other items that are prime targets for an IRS examination of certain trust arrangements.
Outline
- Applicable tax rules and trust structures
- Recent IRS enforcement initiatives
- Trust filing requirements
- Domestic trusts
- Foreign trusts
- Best practices for estate planners and taxpayers
Benefits
The panel will discuss these and other key issues:
- What are the applicable tax rules and reporting obligations for domestic and foreign trusts?
- What are the areas of focus by the IRS regarding abusive trust arrangements and transactions?
- How can estate planners and taxpayers avoid potential audit triggers in trust structuring and transactions?
- What are the key provisions or modifications available for trust documents in light of the IRS crackdown on trust arrangements?
Faculty

John R. Bedosky
Partner
Hinman Howard & Kattell
Mr. Bedosky is a partner in Hinman, Howard & Kattell’s Trusts, Estates, and Wealth Planning Practice Group.... | Read More
Mr. Bedosky is a partner in Hinman, Howard & Kattell’s Trusts, Estates, and Wealth Planning Practice Group. He has extensive experience in a variety of estate planning matters including business succession planning; family wealth accumulation, preservation and transfer planning; estate and trust administration; fiduciary litigation; and related taxation matters.
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Cliff Capdevielle
Managing Attorney
Moskowitz
Mr. Capdevielle has been developing sophisticated tax planning strategies and resolving tax disputes for clients more... | Read More
Mr. Capdevielle has been developing sophisticated tax planning strategies and resolving tax disputes for clients more than two decades. As lawyer, accountant, longtime instructor and adjunct professor, Mr. Capdevielle formulates strategies to utilize the ever-changing array of federal and state tax laws – and relevant treaties – to clients’ benefit. This includes comprehensive counsel to businesses adapting to sweeping tax law changes enacted in 2017, and ongoing work with business owners and other individual taxpayers seeking to preserve assets through trust and estate planning.
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Matthew L. Roberts, J.D., LL.M.
Principal
Freeman Law
Mr. Roberts devotes a substantial portion of his legal practice to helping his clients successfully navigate and... | Read More
Mr. Roberts devotes a substantial portion of his legal practice to helping his clients successfully navigate and resolve their federal tax disputes, either administratively, or, if necessary, through litigation. As a trusted advisor he has provided legal advice and counsel to hundreds of clients, including individuals and entrepreneurs, non-profits, trusts and estates, partnerships, and corporations.
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