The Perils of Civil and Criminal Tax Penalties: What You Need to Know
The IRS has increasingly and more aggressively been asserting tax penalties. Criminal tax enforcement will be expanding. The program will give practitioners insight of what lies ahead in terms of tax penalties in the coming years. Although the civil and criminal tax penalties are different, there are similarities and IRS can invoke both sanctions against a single taxpayer, making it important for taxpayers to know the basic details of penalty assessments.
Listen as a panel of distinguished tax professionals organized by The Knowledge Group provide the audience with an overview of the civil and criminal tax penalties. Speakers will also offer helpful insights on how to avoid the risks of penalties and how practitioners can protect themselves and their clients from such perils.
In a LIVE webcast, the speakers will discuss:
- Civil and Criminal Tax - Overview
- The Relationship Between Civil and Criminal Tax Fraud
- Nuts and Bolts of Civil and Criminal Tax Penalties
- The Perils of Civil and Criminal Tax Penalties
- Understanding Penalty Assessments
- Recent Statistics
- Best Practices
Culp Elliott & Carpenter P.L.L.C.
Hochman, Salkin, Rettig, Toscher & Perez, P.C.
Mather Law Corporation
- The Internal Revenue Service is Increasingly Asserting Civil Penalties and Criminal Tax Enforcement Will be Expanding.
- The Program will Cover the major civil penalties, including International Reporting Penalties
- Experienced Practitioners Will Discuss How to Avoid Penalties; how to defend against penalties at the examination, appeals and in litigation using the "reasonable cause" defense and how to avoid potential privilege waivers in defending against penalties.
- The Program will cover the Civil Fraud Penalty and Penalties for Criminal Tax Fraud and the Differences Between Civil Fraud and Criminal Tax Fraud
- The Program will discuss the major criminal tax violations, including the pending U.S. Supreme Court case of Marinello dealing with Obstruction of IRS Administration and the role of the Federal Sentencing Guidelines in Criminal Tax Enforcement.
- The panel will also discuss the sensitive IRS tax audit, the fraud referral process and how to avoid the referral to the IRS Criminal Investigation Division.
Who Should Attend:
- Tax Practitioners and Professionals
- Tax Advisers
- Tax Directors
- Tax Managers
- Tax Attorneys
- Tax Consultants
- Tax Compliance Officers
- Other Related and Interested Professionals
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 …
Steven Toscher is a tax attorney and principal of the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, California where he specializes in civil and criminal tax litigation. Mr. Toscher is a California State Bar Certified Tax Specialist in Taxation and served as a Trial Attorney with the Tax Division of the United States Department of Justice where he received its Outstanding Attorney Award. He is a summa cum laude graduate of the University of San Diego School of Law and a former Internal Revenue Agent. He is a co-author of BNA Bloomberg’s Tax Crimes Portfolio, 636-3rd. Mr. Toscher is currently serving as co-lead counsel in the Estate of Michael Jackson v. Commissioner, where the Tax Court recently issued a significant ruling on procedural requirements the IRS must follow in order to assert civil penalties.
Steven Toscher is a tax attorney and principal of the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C., …
Steve received a BBA in accounting at the University of Iowa, became a Certified Public Accountant and had stints with a public accounting firm and corporate accounting departments. Steve then graduated from the University of Iowa Law School. For five years, Steve was a senior trial attorney with District Counsel, Internal Revenue Service in Los Angeles and San Francisco. Since 1987, Steve has focused his law practice on resolution of tax disputes for taxpayers. Steve has dozens of reported United States Tax Court decisions and has resolved thousands of Tax Court cases. He has authored BNA Tax Management Portfolios on federal tax collection and audit procedures for pass-thru entities.
Steve received a BBA in accounting at the University of Iowa, became a Certified Public Accountant and had stints with …
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Method of Presentation:
On-demand Webcast; Group-Internet Based
Basic knowledge in tax laws
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
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About Culp Elliott & Carpenter P.L.L.C.
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 Hochman, Salkin, Rettig, Toscher & Perez, P.C.
Hochman, Salkin, Rettig, Toscher & Perez, P.C., is internationally recognized for excellence, integrity and the ability to achieve the best possible results for our clients throughout the world. For more than 55 years, our experienced tax lawyers, recognized for their outstanding tax-related credentials, have been leaders in handling sophisticated civil and criminal tax matters. The firm’s extensive tax expertise includes a strong emphasis in numerous areas of civil tax disputes as well as defending criminal tax investigations and prosecutions. Our tax lawyers are routinely involved in complex civil tax examinations on behalf of wealthy individuals and closely held entities as well as large corporations involving both domestic and foreign tax related issues.
About Mather Law Corporation
Mather Law Corporation is devoted exclusively to representing clients in federal and California tax disputes. Our attorneys, CPAs and enrolled agents represent taxpayers in many pending cases before the United States Tax Court, the federal district courts, the federal circuit courts of appeal, and the California Superior Court. We literally have decades of experience handling every conceivable type of tax controversy.