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The Increasingly Complex Tax Controversy and Litigation Landscape: Best Strategies to Avoid Risk and Pitfalls

The Increasingly Complex Tax Controversy and Litigation Landscape: Best Strategies to Avoid Risk and Pitfalls

Live Webcast Date: Thursday, March 08, 2018 at 3:00 pm - 4:30 pm (ET)
Taxation Recording

$99.00 - 1.5 Credit Hours

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If CE credit is needed, there is a minimal fee for processing. Please select accordingly. Attorneys who need CLE credit for IL must register 3 days prior to the live event. Registration received thereafter will not qualify for approved CLE credit. For more info, email [email protected].

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Partner Firms

Click firm logo/firm name to learn more

Hochman, Salkin, Rettig, Toscher & Perez, P.C.
Restivo Monacelli LLP
Teig Lawrence, P.A.

Hochman, Salkin, Rettig, Toscher & Perez, P.C.

HOCHMAN SALKIN RETTIG TOSCHER & PEREZ, PC, is internationally recognized for excellence, integrity and the ability to achieve the best possible results for its clients throughout the world. Its experienced tax lawyers have outstanding tax-related credentials and are routinely recognized as leaders in handling all aspects of sophisticated tax controversies and criminal tax matters.

The firm specializes in expediting favorable resolution strategies for administrative tax controversies and tax disputes with the federal, state and local taxing authorities, federal and state civil tax litigation, defense of criminal tax investigations and prosecutions, white collar criminal defense, and family wealth transfers and related planning opportunities. Its attorneys routinely handle representations involving complex and sensitive issue tax examinations and administrative appeals, voluntary and “scorched earth” tax collection problems, responding to summonses and subpoenas, and trials and appeals before all Federal courts.  It has a long history of successfully resolving the most sensitive, complex tax matters for our clients in the most efficient, cost-effective manner.

Few other firms have the similar firm-wide background and experience of Hochman Salkin’s tax lawyers derived from positions at the U.S. Department of Justice, Internal Revenue Service, U.S. Tax Court and private practice. Coupled with strong working relationships with these government agencies, Hochman Salkin provides effective representation of its clients when facing the most complex or sensitive tax-related matters.

Website: http://www.taxlitigator.com/

Restivo Monacelli LLP

Restivo Monacelli provides professional accounting and auditing, state, federal and international tax services, estate and wealth preservation, strategic planning/consulting, business valuation, and business outsourcing solutions to clients throughout the United States. Established more than two decades ago with a uniquely different business model than traditional accounting firms, Restivo Monacelli leverages its first-hand business experience and financial expertise to provide forward-thinking solutions that drive growth and long-term success for its clients.

With a team of over 30 professionals and specialists at clients’ fingertips, Restivo Monacelli deliver all the resources of a much larger firm with the responsiveness and personal service normally only found in a smaller, boutique firm. Restivo Monacelli stays ahead of the curve on industry trends, regulations and resources in order to guide clients across an ever-changing landscape. As a result, the firm has consistently grown and evolved to be a best-in-class tax, accounting and business advisory firm for clients nationwide. For more information, visit www.rm-llp.com

Website: https://www.rm-llp.com/

Teig Lawrence, P.A.

Teig Lawrence, P.A. (TLPA) was founded in the year 2000 to serve as a tax law firm focusing on Non-Compliant Foreign Accounts, IRS Offshore Voluntary Disclosures, Tax Collection Procedure, Penalty Relief, IRS Examinations, and, IRS Whistleblower Claims.

Believing that best decisions are made by people with the best information, TLPA created mytaxlaw.com as means of aggregating the latest worldwide news related to Swiss bank secrecy and the UBS case in 2008.  mytaxlaw.com is now tracking the latest news related to more than a dozen offshore banks, Bitcoin, Panama Papers, Bahamas Leaks, Singapore Enforcement Initiatives, FATCA, official IRS & DOJ announcements, and, Whistleblower actions.  

TLPA has successfully represented clients in every offshore voluntary disclosure program offered by the IRS including the 2014 OVDP, 2012 OVDP, 2011 OVDI, 2009 OVDP, LCCI, and, 2003 OVCI.

Website: http://mytaxlaw.com/

Speakers
Robert Horwitz

Robert HorwitzAttorneyHochman, Salkin, Rettig, Toscher & Perez, P.C.

Robert Horwitz is a principal with Hochman, Salkin, Rettig, Toscher & Perez, PC, in Beverly Hills, CA, where he specializes in the representation of clients in civil and...

Robert Horwitz is a principal with Hochman, Salkin, Rettig, Toscher & Perez, PC, in Beverly Hills, CA, where he specializes in the representation of clients in civil and criminal tax cases. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and as Chair of the Taxation Section for 2015-2016. Before entering private practice, Mr. Horwitz was a trial attorney in the U.S. Department of Justice Tax Division and the U.S. Attorney's Office in Los Angeles.

Mr. Horwitz has been a speaker on tax matters at the Annual Meeting of the Taxation Section of the California Bar, the ABA Section of Taxation Mid-Year Meeting, the UCLA Tax Controversy Institute, and the California State Bar Annual Meeting. He has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the CCH Journal of Tax Practice & Procedure, the Federal Lawyer (the publications of the Federal Bar Association), the California Tax Lawyer and the Camlifornia Journal of Tax Litigation.

Mr. Horwitz is a member of the bars of California and Illinois. He is admitted to practice before the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018. He is member of the American College Tax Counsel and of the Planning  Committee of the UCLA Tax Controversy Institute.

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Bruce A. Desrosiers, CPA, MST

Bruce A. Desrosiers, CPA, MSTPartnerRestivo Monacelli LLP

Bruce Desrosiers is a Partner of Restivo Monacelli LLP, an innovative tax, accounting, accounting and business advisory firm that is headquartered in Providence, RI with offices in...

Bruce Desrosiers is a Partner of Restivo Monacelli LLP, an innovative tax, accounting, accounting and business advisory firm that is headquartered in Providence, RI with offices in Foxboro, MA and Boca Raton, FL.

As a Certified Public Accountant (CPA) with more than 20 years of aacounting, tax, plus business experience, Bruce is a key member of the firm’s growing tax compliance and consulting practice.

Bruce navigates through complex and ever-changing tax laws to guide a variety of industry groups, including privately held businesses, estates and trusts, individuals and non-profit organizations. Clients leverages his expertise and forward-thinking approach to avoid tax reporting and compliance errors that have the potential to increase audit risk and damage a company’s reputation with its customers and the marketplace.

Widely recognized as a thought leader on tax related topics, Bruce is frequent speaker and presenter, and is the co-author of The Practice Cost of Segregation Analysis. He also plays a significant role in the development and training of new and existing professional staff. Bruce and his team  leverage their depth of expertise to advise clients on tbe latest tax laws and deliver creative, highly-tailored strategies to minimizes taxes and maximize bottom line results.

Bruce begin his career with Ernst & Young, LLP in 1994 before joining Sullivan & Company CPA’s LLP in 1997. He continued with the firm through its merger with West Hartford based Blum Shapiro in 2013, where he served as Tax Director unitil joining Restivo Monacelli LLP.

A graduate of Providence College, Bruce received a Bachelor of Science in Accounting and a Master of Science in Taxation from Bryant University. He is a member of the American Institute of Certified Public Accoutants (AICPA), Tax Section and the Rhode Island Society of Certified Public Accountants (RISCPA).

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Teig Lawrence

Teig LawrenceTax AttorneyTeig Lawrence, P.A.

Teig Lawrence has spent 20 years building an international tax practice concentrating on non-compliant foreign accounts, IRS offshore voluntary disclosures, IRS streamlined...

Teig Lawrence has spent 20 years building an international tax practice concentrating on non-compliant foreign accounts, IRS offshore voluntary disclosures, IRS streamlined procedures, IRS examinations, tax collection procedure, penalty protests, and large dollar whistleblower claims. 

In 2009, Teig, developed mytaxlaw.com to track and aggregate the latest worldwide tax enforcements news.  mytaxlaw.com has become a leading provider of offshore enforcement news and regularly receives hits from approximately 40 different countries per month.

Teig is an expert in electronic research.  He served as Adjunct Professor of Federal Tax Research at the University of Miami School of Law Graduate Program In Estate Planning from 2001 thru 2008.  Prior to going into private practice, Teig worked for Deloitte & Touche, Westlaw, Merrill Lynch, and, PaineWebber.

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SEGMENT 1:
Robert Horwitz, Attorney
Hochman, Salkin, Rettig, Toscher & Perez, P.C.
  1. IRS Investigation of the Use of Cryptocurrencies to Evade Tax and Launder Money
  2. Beginning of the New Partnership Audit Regime and How It May Impact Taxpayers
  3. Increased IRS Scrutiny of Micro-Captives after Avrahami v. Commissioner
  4. International Tax Enforcement Still a Priority with Formation of CI's International Tax Enforcement Group
  5. IRS Tries to Narrow Tax Gap by Clampdown on Employment Taxes
  6. DOJ Pushes Courts to Adopt Rule that Constructive Knowledge = Willful in FBAR Cases
  7. Use of the APA to Challenge IRS Regulations in Light of Altieri v Commissioner
  8. The Overuse of Penalties by the IRS

SEGMENT 2:
Bruce A. Desrosiers, CPA, MST, Partner
Restivo Monacelli LLP

SEGMENT 3:
Teig Lawrence, Tax Attorney
Teig Lawrence, P.A.
  1. The Newly Formed IRS Letter 6019 Group -  This Group Is Mailing Letters (Letter 6019) to Taxpayers with Suspected Non-Compliant Foreign Accounts and Providing 3 Options for Getting Back Into Compliance. 
  2. Congressional Clarification of “Collected Proceeds” Very Favorable to Whistleblowers under the IRS Whistleblower Program & Other Updates. 
  3. The Use of Behavioral Insights (Behavioral Sciences) by IRS in Driving Tax Compliance.

Join a panel of key thought leaders and tax professionals assembled by The Knowledge Group as they explain the current trends, recent legislation, and recent court rulings involving tax controversies.  Speakers will also provide practical strategies for dealing with the IRS in a rapidly evolving enforcement climate.

As tax authorities and taxpayers continue to encounter tax challenges and complexities, tax controversies have become more frequent.  A key international trend that stands out is the emerging conflict between transparency, tougher tax enforcement, and, issue based examinations.  To obtain the best results for your clients, it is important to understand the latest IRS positions with respect to emerging issues as well as IRS enforcement initiatives which are currently underway. 

Key topics include:

  • IRS Investigation of the Use of Cryptocurrencies to Evade Tax and Launder Money
  • Beginning of the New Partnership Audit Regime and How It May Impact Taxpayers
  • Increased IRS Scrutiny of Micro-Captives after Avrahami v. Commissioner
  • International Tax Enforcement Still a Priority with Formation of CI's International Tax Enforcement Group
  • IRS Tries to Narrow Tax Gap by Clampdown on Employment Taxes
  • DOJ Pushes Courts to Adopt Rule that Constructive Knowledge = Willful in FBAR Cases
  • Use of the APA to Challenge IRS Regulations in Light of Altieri v Commissioner
  • The Overuse of Penalties by the IRS
  • Record keeping requirements to avoid the controversy
  • Section 199A The 20% deduction-Tracking hours for passive activity rules
    • Non-passive
    • Real Estate Professional
  • Wages verses contractor payments-classification changes
  • Meals verses Entertainment
  • Reimbursements to employees- accountable plans
  • The Newly Formed IRS Letter 6019 Group -  This Group Is Mailing Letters (Letter 6019) to Taxpayers with Suspected Non-Compliant Foreign Accounts and Providing 3 Options for Getting Back Into Compliance 
  • Congressional Clarification of “Collected Proceeds” Very Favorable to Whistleblowers under the IRS Whistleblower Program & Other Updates
  • The Use of Behavioral Insights (Behavioral Sciences) by IRS in Driving Tax Compliance

This is a must attend event for anyone interested in understanding the significant risk issues relating to Tax Controversy and Litigation in the U.S. and Canada.

During this Webcast, you will hear:

  • Detailed guidance explained by the most qualified key leaders & practitioners.
  • Hear directly from key thought leaders
  • Interact directly with panel during Q&A

Be in the know! Click the “register” button as space is limited. Significant discounts apply to early birds.

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