Tax Controversy: Handling Audits, Appeals, Litigation, and Collections for Clients
Our panel of key thought leaders and practitioners will provide a comprehensive discussion and advice on how to deal with Tax Controversies: Handling Audits, Appeals, Litigation, and Collections for Clients. This event is designed to help lawyers, legal counsel, and tax and accounting practitioners understand the fundamental procedures, rules and regulations, risks and pitfalls, and best practices in handling government taxation disputes.
Key topics include:
- The IRS Audit Process
- Compliance Regulations
- Delinquency, Risk of Summons, Avoidance
- Tax Return Examination: Client Advice
- IRS Exam: Closure or Settlement in Appeals
- Tax Case Derailment
- Best Practices in Resolving Tax Cases
- Auditing Techniques
Gary Stirbis, JD, LLM, Director
Moss Adams LLP
- IRS staffing issues, morale, statistics
- Info on different levels of the agency
- Small Business and LBI initiatives
- LBI quality cam process / exam strategy
Seth G. Cohen, Partner
Withers Bergman LLP
- OVDP / what an exam looks like
- Asia –China, Hong Kong, Singapore – voluntary disclosure program
- What are IRS powers to investigate, collect
David A. Shuster, Tax Principal, Director of Tax Controversy Services
Grassi & Co.
- Appeals and other options available after disagreement at audit level
- Collection, due process
- Strategies when you cannot do anything else with the auditor (tax court, et al)
- Litigation, tax court, what a practitioner may be up against
- New York State
Laura L. Gavioli, Partner
- Handling requests in an exam for information held internationally
- IRS LB&I's new IDR procedures as relevant to international requests
- IRS alternatives for seeking taxpayer information internationally (treaty requests, etc.)
- Handling privileged information in an exam, both domestically and internationally
Who Should Attend:
- Tax Attorneys
- Tax Directors
- Audit Consultants
- Account and Audit Preparers
- Enrolled Agents
- Other Related/Interested Professionals
Laura Gavioli is a partner in the tax practice of a major US law firm. She defends individuals, partnerships, and corporations in white collar prosecutions, civil tax cases, IRS controversies and complex financial litigation. Laura currently represents numerous taxpayers with both civil and criminal exposure regarding their reporting of offshore financial assets and has represented clients involved in some of the largest criminal tax evasion cases ever brought in the US. Her experience includes significant taxpayer victories in U.S. Tax Court and federal district court eliminating IRS penalties due to the taxpayers' good faith and reasonable cause. She has also litigated numerous cases addressing complex jurisdictional questions under taxation statutes and setting taxpayer-friendly precedent regarding taxation statutes of limitations.
Laura Gavioli is a partner in the tax practice of a major US law firm. She defends individuals, partnerships, and …
David Shuster is a Tax Principal at Grassi & Co., and serves as the firms Director of Tax Controversy Services. His practice focuses on advising, representing and defending clients in their controversies with the IRS and the state taxing authorities. David also advises corporations, partnerships, private foundations, public charities and individuals in federal and state tax planning and compliance.
David began his career at the United States Department of Justice, where he was appellate counsel to the government in a wide variety of tax cases. There, he briefed and orally argued cases in nearly all of the federal circuit courts of appeals. He also advised and assisted the Solicitor General’s office in its Supreme Court litigation.
David received his JD and LLM in Taxation from New York University School of Law and his Bachelor of Science in Electrical Engineering from the University of Michigan.
David Shuster is a Tax Principal at Grassi & Co., and serves as the firms Director of Tax Controversy Services. …
Seth Cohen, Partner at law firm Withers Bergman LLP, is an experienced tax controversy and procedure attorney who has represented individuals and entities from start-up to public companies. He has in-depth knowledge of the laws applicable to, and the policies and procedures followed by, the IRS, state and local taxing authorities. Seth has extensive experience representing clients in tax controversies, including tax examinations and appeals; tax litigation; and voluntary disclosure agreements (including offshore and domestic). Further, he frequently assists his clients in tax collection defense, including collection administrative appeals, installment agreements and offers in compromise. Seth is an adjunct professor of tax and law in the University of New Haven’s Master of Science in Taxation and Executive MBA programs, and a frequent contributor to ABA comments made on tax legislation.
Seth Cohen, Partner at law firm Withers Bergman LLP, is an experienced tax controversy and procedure attorney who has represented …
Gary is the director of the Tax Controversy & Dispute Resolution Practice at Moss Adams LLP. He manages major IRS engagements for clients and handles all aspects of representation before the IRS, including audits, appeals, collections, excise taxes, private letter rulings, and various procedural matters.
Gary previously worked for the Office of Chief Counsel for the Internal Revenue Service, providing advice to IRS field agents and the Office of Appeals on all matters pertaining to the interpretation, administration, and enforcement of Internal Revenue laws. He further represented the IRS in the United States Tax Court and provided other legal support needed by IRS personnel.
Gary is the director of the Tax Controversy & Dispute Resolution Practice at Moss Adams LLP. He manages major IRS …
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Dentons is a global law firm driven to provide clients with a competitive edge in an increasingly complex and interconnected marketplace. Dentons was formed by the March 2013 combination of international law firm Salans LLP, Canadian law firm Fraser Milner Casgrain LLP (FMC) and international law firm SNR Denton, and builds on the solid foundations of these three highly regarded law firms. Clients benefit from approximately 2,600 lawyers and professionals in more than 75 locations spanning 50-plus countries across Africa, Asia Pacific, Canada, Central Asia, Europe, the Middle East, Russia and CIS, the UK and the US who are committed to challenging the status quo to offer creative business and legal solutions.
About Grassi & Co.
Grassi & Co. is a premier professional service organization specializing in accounting, auditing, tax, technology, and business consulting services. Grassi & Co. has offices in Manhattan & Long Island, NY as well as Milan, Italy. Grassi & Co. has been ranked among the Top 100 largest firms in the U.S. by both INSIDE Public Accounting and Accounting Today, the Top 20 largest firms in the New York Metropolitan area by Crain’s New York Business and the Top 10 largest firms on Long Island by Long Island Business News. Grassi & Co. specializes in professional services for the Construction, Architecture & Engineering, Financial Services, Manufacturing & Distribution, Retail, Technology, Media & Telecommunication, Transportation, Not-for-Profit, and Healthcare industries, among others.
About Withers Bergman LLP
Withers Bergman LLP and its affiliated entities (collectively Withersworldwide) have advised successful individuals, families, companies and institutions on their business and personal legal needs both at home and abroad for more than 100 years. The firm has some 350 attorneys in 12 offices spread across Europe, US, the Caribbean and Asia. The firm represents private clients and private enterprises with respect to all their personal and commercial legal needs. Our international locations enable us to provide truly global integrated solutions tailored to our clients needs from our offices in New York, San Francisco, New Haven, Greenwich Connecticut, London, Milan, Singapore, Hong Kong, Geneva, Zurich, Padua, and the British Virgin Islands.
About Moss Adams LLP
One of the largest accounting and business consulting firms in the nation, Moss Adams LLP provides accounting, tax, and consulting services to public, private, and not-for-profit enterprises in more than 30 different industries. Founded in 1913 and headquartered in Seattle, Moss Adams has 24 locations in Washington, Oregon, California, Arizona, New Mexico, Texas, and Kansas and serves clients that do business in all 50 states and over 95 countries and territories around the world.
Assurance services include audits, accounting, internal controls, business risk management, royalty compliance, and employee benefit plans. Tax services include federal, state, and local tax planning and compliance; international tax planning and compliance; cost segregation; and research and development tax credits. Moss Adams also provides consulting and advisory services for mergers and acquisitions, corporate finance, valuations, business owner succession, business planning, litigation and forensic accounting, information technology integration and reviews, and compensation.
Moss Adams offers additional services such as investment banking and asset management by drawing on our two affiliate companies, Moss Adams Capital LLC and Moss Adams Wealth Advisors LLC.