Federal Tax Controversy: Demystifying Trends, Developments, and Critical Issues
Despite deadline extensions and a challenging environment caused by the COVID-19 outbreak, the Internal Revenue Service (IRS) continues its strict tax enforcement. Audit activity is expected to be more aggressive as governments grapple to cover the current budget deficit and falling revenues. However, businesses facing assessments or controversies may be able to settle cases more favorably under the present financial crisis.
Thus, the need for a prompt and professional legal advice remains crucial even amidst the pandemic. Tax professionals should stay conversant with the ever-changing IRS enforcement strategies and legal revamps to successfully address their clients’ potential or ongoing tax disputes. Corporate executives should be equally current to take advantages of new opportunities to reduce federal tax liabilities.
In this LIVE Webcast, seasoned tax litigators W. Curtis Elliott, Jr. (Culp, Elliott & Carpenter, PLLC) and Barry A. Furman (Fineman Krekstein & Harriswill) will provide the audience with an in-depth analysis of the recent developments in tax enforcement. Speakers will also outline the leading practices to help tax professionals represent clients before the IRS and litigate tax controversies, and help tax professionals and corporate executive manage possible risks and reduce liabilities.
Key topics include:
- Recent IRS Trends and Developments
- Implications of COVID-19 to Tax Controversies
- Action Items for Tax Professionals
- Best Practices in Defending Against Tax Disputes
Barry A. Furman, Of Counsel
Fineman Krekstein & Harris
- Covid-19 news releases such as IRS stops mailing notices to taxpayers with balances due
- Guidance to Taxpayer Advocate Service employees on types of cases accepted
- Targeting auditing high net worth taxpayers and tax targets
- New centralized partnership audit regime
- Overview of tax litigation forums and recent significant cases such as Kisor deference in tax controversies
W. Curtis Elliott, Jr., Partner
Culp, Elliott & Carpenter, PLLC
- Procedures for Remote Trials in the U.S. Tax Court;
- Changes to the IRS’s Policies for Cases Designated for Litigation.
- IRS Recent Enforcement Steps Involving Conservation Easements.
Who Should Attend:
- Tax Managers and Directors
- Tax Lawyers and Consultants
- Tax Accountants
- Tax Advisors
- Tax Compliance Officers
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).
Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience …
For the past 35 years, Barry has counseled a wide range of business clients regarding tax, corporate, employment, estates and trusts, health care, and real estate. After serving as a law clerk for a federal judge, Barry was a senior trial attorney in the Office of Chief Counsel, Internal Revenue Service. There, Barry represented the Commissioner of IRS in many significant cases and awarded several merit awards. In private practice, Barry has continued a tax litigation practice, representing clients before the IRS, state tax agencies, U.S. Tax Court, U.S. Claims Court, and U.S. Circuit Courts of Appeal. He also represents clients in IRS and state tax examinations. In private practice, his peers have rated Barry as “Esteemed.”
For the past 35 years, Barry has counseled a wide range of business clients regarding tax, corporate, employment, estates and …
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Method of Presentation:
General knowledge of tax laws
NY Category of CLE Credit:
Areas of Professional Practice
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About Culp, Elliott & Carpenter, PLLC
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.
About Fineman Krekstein & Harris
For more than 35 years, the law firm of Fineman Krekstein & Harris P.C. has represented individuals, businesses, nonprofit organizations and governmental agencies throughout the region. Deeply rooted in the community, the firm’s attorneys understand the rules and appreciate the nuances specific to courts, government structure and legal and business interests in the metropolitan Philadelphia area. The firm provides a full-range of legal services and business solutions. Its litigation attorneys handle complex civil and commercial litigation, products liability, toxic torts, transportation and insurance matters. Its business attorneys advise clients on such matters as taxes and tax disputes, employment disputes, real estate matters and finance. Its attorneys work collaboratively to provide a comprehensive solution designed to address clients’ specific needs. The firm is dedicated to the practice of relationships. Everyone at Fineman Krekstein & Harris is committed to providing top quality service to the firm’s clients through hard work and personal attention.