Learn practice tips for representing clients that have been selected for examination.
The IRS has made high net worth individuals living across the globe a primary area of focus for tax enforcement. Who are these individuals? Why is the IRS targeting them? What resources are being brought to bear by the government in these cases, and how does one minimize the potential harm if the IRS has you in its sights? This course will help U.S. tax practitioners advise their global high net worth clients on how to stay off of the IRS's radar screen, as well as provide practice tips for representing such a client that has been selected for examination. Additionally, this course will cover what to do when a client has negligently or intentionally failed to meet their tax reporting obligations, but the IRS is not yet aware of the non-compliance.
Agenda
Faculty
Melissa L. Wiley
Lowenstein Sandler LLP
- Partner, Lowenstein Sandler LLP
- Experience representing clients in all levels of the IRS administrative process, as well as in tax litigation matters; served as subject matter expert on a variety of tax controversy topics as a member of a Big 4 national tax department; acted as internal counsel to a Big 4 accounting firm on matters related to the tax practice
- Frequent speaker on topics related to IRS examinations, penalties, ethics, and return preparers
- Regent, American College of Tax Counsel; vice-chair of Appointments to the Tax Court and Argret Fellowship committees, American Bar Association Section of Taxation; Chair, Tax Audits & Litigation Committee, D.C. Bar Tax Section; vice-chair of IRS Advocacy & Relations and National Tax Committees, AICPA
- J.D. degree, Georgetown University Law Center; B.S. degree in actuarial science, The College of Insurance
- Can be contacted at [email protected] or 202-862-3790
Niles A. Elber
Caplin & Drysdale
- Member, Tax Controversy Practice, Caplin & Drysdale’s Washington, D.C. office
- More than 20 years of experience representing clients in civil and criminal tax controversies; practice is broad, ranging on the civil side from IRS examinations, appeals matters, and proceedings in federal court while on the criminal side handling both administrative and grand jury tax investigations; has assisted hundreds of clients with their voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts.
- Speaks regularly to accountants and tax lawyers on a variety of tax controversy topics
- Co-authored BNA Tax Management Portfolio titled: Report of Foreign Bank and Financial Accounts (FBAR)
- Fellow, American College of Tax Counsel; member, American Bar Association Section of Taxation – past chair, Civil and Criminal Tax Penalties Committee
- J.D. degree, Tulane University; LL.M. degree in tax, New York University
- Can be contacted at [email protected] or 202-862-7827
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