HomeWebcastCivil & Criminal Tax Penalties: Procedures and Defenses in 2018
Online CPE Criminal Tax CLE

Civil & Criminal Tax Penalties: Procedures and Defenses in 2018

Live Webcast Date: Tuesday, June 05, 2018 from 3:00 pm to 4:30 pm (ET)
Taxation (CPE)Recording

Online CPE Criminal Tax

Join us for this Knowledge Group Online CPE Criminal Tax Webinar. In this Webcast, join a seasoned panel of thought leaders and professionals assembled by The Knowledge Group as they bring the audience to a road beyond the basics of civil and criminal tax penalties. Speakers will also present an in-depth discussion of the fundamentals as well as recent developments surrounding this significant topic. They will also provide strategies and practical tips to help avoid risks, pitfalls and legal threats involving civil and criminal tax penalties.

Key topics include:

  • Civil and Criminal Tax: A Refresher
  • Scope and Legal Considerations
  • IRS Policies and Procedures on Tax Penalties
  • Common Risk and Pitfalls
  • Trends and Updates
  • Best Defense Strategies

Agenda

SEGMENT 1:
Ian M. ComiskyPartner
Fox Rothschild LLP

  • Update on United States v. Marinello, ___ U.S. ___ 138 S.Ct. 1101 (2018)
  • Update on FBAR Reporting, including FBAR Penalty Issues
  • Criminal Charges as a result of FATCA
  • 2017 Tax Bill penalty and related changes

SEGMENT 2:
Matthew D. LeePartner
Fox Rothschild LLP

  • International information return penalties, including Forms 5471, 926, 8865, 3520, and 3520-A
  • Impact of failure to file international information returns on statute of limitations
  • Current developments with respect to the Trust Fund Recovery Penalty for employment taxes
  • IRS First Time Penalty Abatement Program
  • IRS Passport Revocation Program

SEGMENT 3: 
W. Curtis Elliott, Jr.Partner
Culp, Elliott & Carpenter, PLLC

  • Requirements of written approval for penalties
  • Using CPA as a fact witness for penalty abatement
  • Substantial authority penalties

Who Should Attend

  • Tax Practitioners and Professionals
  • Tax Advisers
  • Tax Directors
  • Tax Managers
  • Tax Attorneys
  • Tax Consultants
  • Tax Compliance Officers
  • Tax Accountants

Online CPE Criminal Tax

SEGMENT 1:
Ian M. ComiskyPartner
Fox Rothschild LLP

  • Update on United States v. Marinello, ___ U.S. ___ 138 S.Ct. 1101 (2018)
  • Update on FBAR Reporting, including FBAR Penalty Issues
  • Criminal Charges as a result of FATCA
  • 2017 Tax Bill penalty and related changes

SEGMENT 2:
Matthew D. LeePartner
Fox Rothschild LLP

  • International information return penalties, including Forms 5471, 926, 8865, 3520, and 3520-A
  • Impact of failure to file international information returns on statute of limitations
  • Current developments with respect to the Trust Fund Recovery Penalty for employment taxes
  • IRS First Time Penalty Abatement Program
  • IRS Passport Revocation Program

SEGMENT 3: 
W. Curtis Elliott, Jr.Partner
Culp, Elliott & Carpenter, PLLC

  • Requirements of written approval for penalties
  • Using CPA as a fact witness for penalty abatement
  • Substantial authority penalties

Online CPE Criminal Tax

Online CPE Criminal Tax

Matthew D. LeePartnerFox Rothschild LLP

Matthew D. Lee is a partner in the Philadelphia office of Fox Rothschild LLP.  He is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense and federal tax controversies. He has extensive experience in advising clients on issues regarding foreign bank account reporting (FBAR) obligations, the Foreign Account Tax Compliance Act (FATCA), and the Internal Revenue Service’s Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures. He has represented hundreds of U.S. taxpayers with undisclosed offshore bank accounts and assets. Mr. Lee has published numerous articles regarding the IRS voluntary disclosure programs and FBAR and FATCA reporting obligations and speaks frequently on these topics. He has also represented clients in all stages of proceedings before the Internal Revenue Service, including audits, appeals, and collections, and Tax Court and district court litigation. Mr. Lee also has experience in conducting corporate internal investigations and advising clients as to corporate compliance issues involving the Bank Secrecy Act, the USA Patriot Act, FATCA, and anti-money laundering laws and regulations. Mr. Lee has represented corporations and individuals in criminal investigations involving tax, money laundering, health care, securities, public corruption, and fraud offenses, and has significant experience in handling all stages of federal litigation including trials and appeals. Mr. Lee is the author of Foreign Account Tax Compliance Act Answer Book 2016 (Practising Law Institute) and publishes a blog entitled Tax Controversy Sentinel (https://taxcontroversy.foxrothschild.com/).  

Online CPE Criminal Tax

Ian M. ComiskyPartnerFox Rothschild LLP

Ian M. Comisky is a litigation partner at Fox Rothschild LLP with more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense and complex commercial disputes. Ian concentrates his practice in representing individuals and entities with respect to U.S. tax and foreign asset reporting obligations under FBAR and FATCA as well as other information reporting requirements. He also counsels individuals and corporations in civil audits and criminal investigations . Ian is a co-author of the two-volume treatise Tax Fraud and Evasion. He was elected in 1995 to the American College of Tax Counsel and is an adjunct professor at the University of Pennsylvania Law School teaching a course that covers FBAR reporting and related issues. Fox Rothschild is a full-service law firm with 21 offices coast to coast. Key practice areas include Bankruptcy, Corporate, Gaming, Employment, Entertainment, Intellectual Property, Litigation, Privacy & Data Security, Real Estate and Tax.

Online CPE Criminal Tax

W. Curtis Elliott, Jr.PartnerCulp, Elliott & Carpenter, PLLC

Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott's clients include Fortune 500 companies, entrepreneurial companies, estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel, and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics. Mr. Elliott also co-authored the nationally published treatise entitled Valuation Practice in Estate Planning and Litigation (Clark Boardman Callahan, 1994).


Click Here to Read Additional Material

Online CPE Criminal Tax

Course Level:
   Intermediate

Advance Preparation:
   Print and review course materials

Method Of Presentation:
   On-demand Webcast

Prerequisite:
   General knowledge of tax law

Course Code:
   147120

NY Category of CLE Credit:
   Areas of Professional Practice

Total Credits:
    1.5 CLE

No Access

You are not logged in. Please or register to the event to gain access to the materials and login instructions.

About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

Fox Rothschild LLP is a national law firm known for excellent client service and agility in problem solving. Our lawyers provide a full range of services to public and private companies, from startups to multinational corporations, and prominent individuals, including celebrities, athletes, artists and entrepreneurs. Founded more than a century ago, Fox has grown significantly in recent years and is now ranked in the AmLaw 100, with 750 attorneys in 22 offices coast to coast.

Website: https://www.foxrothschild.com/

Culp Elliott & Carpenter, PLLC is a Charlotte, North Carolina tax law firm founded in 1982. It provides innovative tax, and legal solutions that create value for its clients, and helps clients achieve the most important goals in their businesses and lives. The Firm represents high-net-worth individuals, successful entrepreneurs, and corporate business clients. Firm members develop effective strategies to save on taxes, representing clients in the areas of estate planning, real estate and commercial transactions, mergers, acquisitions, restructuring and recapitalizations. Firm members handle civil and criminal tax litigation, and trusts and estates litigation, at all levels of dispute, and represent clients in disputes with the Internal Revenue Service. The Firm serves clients throughout the Southeastern United States.

Website: www.ceclaw.com/

Matthew D. Lee is a partner in the Philadelphia office of Fox Rothschild LLP.  He is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense and federal tax controversies. He has extensive experience in advising clients on issues regarding foreign bank account reporting (FBAR) obligations, the Foreign Account Tax Compliance Act (FATCA), and the Internal Revenue Service’s Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures. He has represented hundreds of U.S. taxpayers with undisclosed offshore bank accounts and assets. Mr. Lee has published numerous articles regarding the IRS voluntary disclosure programs and FBAR and FATCA reporting obligations and speaks frequently on these topics. He has also represented clients in all stages of proceedings before the Internal Revenue Service, including audits, appeals, and collections, and Tax Court and district court litigation. Mr. Lee also has experience in conducting corporate internal investigations and advising clients as to corporate compliance issues involving the Bank Secrecy Act, the USA Patriot Act, FATCA, and anti-money laundering laws and regulations. Mr. Lee has represented corporations and individuals in criminal investigations involving tax, money laundering, health care, securities, public corruption, and fraud offenses, and has significant experience in handling all stages of federal litigation including trials and appeals. Mr. Lee is the author of Foreign Account Tax Compliance Act Answer Book 2016 (Practising Law Institute) and publishes a blog entitled Tax Controversy Sentinel (https://taxcontroversy.foxrothschild.com/).  

Ian M. Comisky is a litigation partner at Fox Rothschild LLP with more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense and complex commercial disputes. Ian concentrates his practice in representing individuals and entities with respect to U.S. tax and foreign asset reporting obligations under FBAR and FATCA as well as other information reporting requirements. He also counsels individuals and corporations in civil audits and criminal investigations . Ian is a co-author of the two-volume treatise Tax Fraud and Evasion. He was elected in 1995 to the American College of Tax Counsel and is an adjunct professor at the University of Pennsylvania Law School teaching a course that covers FBAR reporting and related issues. Fox Rothschild is a full-service law firm with 21 offices coast to coast. Key practice areas include Bankruptcy, Corporate, Gaming, Employment, Entertainment, Intellectual Property, Litigation, Privacy & Data Security, Real Estate and Tax.

Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott's clients include Fortune 500 companies, entrepreneurial companies, estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel, and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics. Mr. Elliott also co-authored the nationally published treatise entitled Valuation Practice in Estate Planning and Litigation (Clark Boardman Callahan, 1994).

Ultimate Value Annual Program

Bring a colleague for only $149, a savings of $50 per additional attendee.

  • Unlimited Access to Live & Recorded Webcasts
  • Instant Access to Course Materials
  • And More!

$199