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.
Learning Objectives
- You will be able to recognize the importance of IRS Campaigns.
- You will be able to recognize the history and current state expectations of the global high wealth group.
- You will be able to identify audit process fundamentals.
- You will be able to identify common areas of audit focus and voluntary disclosure options.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
IRS Campaigns
- History of IRS Campaigns and Discussion of Current State
- Which Currently Active Campaigns Are Most Likely to Affect High-Wealth Taxpayers?
- Focus on High-Income Non-Filers Campaign
Global High Wealth Group: IRS Wealth Squad
- History of the GHW Group
- Current State and Expectations for the Future
Audit Process Fundamentals
- What Are the Common Methods Used by the IRS to Identify Taxpayers for Examination?
- How Are Audits Conducted? - Required Steps, Rules of Engagement, and Best Practices
- What Are Some Common IRS Procedural Missteps That Can Benefit Taxpayers?
Common Areas of Audit Focus
- International Information Reporting (Including Fbars)
- TCJA Compliance
- Foreign Tax Credits
- Reportable Transactions and Required Disclosures
Voluntary Disclosure Options
- Delinquent International Information Return Submission Procedures
- Streamlined Submission Procedures
- Voluntary Disclosure Practice
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Credit
More Program Information
Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last reviewed on December 7, 2023.
Call 1-866-352-9540 for further credit information.
- AIPB 2.0
- This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
CPE/NASBA - QAS Self Study 2.8 including Specialized Knowledge 2.8
- Noggin Guru, Inc. dba Lorman Education Services and BankersHub is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.8 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Specialized Knowledge for 2.8 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
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
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
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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