On December 7, 2021, Megan L. Brackney presents a CLE Program entitled “Preparing for a Tax Controversy: Gearing Up for Increased Tax Audits and Investigations” for the American Law Institute.

Description: In an August letter to IRS Commissioner Charles Rettig, members of Congress asked for increased IRS funding to pursue wealthy tax evaders and improve IRS services for all Americans. If successful, the current budget reconciliation package will deliver this requested funding to the IRS. The downstream effect will have significant impacts on attorneys advising clients in tax, business, or wealth planning matters. They will see increasing numbers of IRS audits, assessments, and tax collections against their high-net worth and business taxpayers, both at home and abroad. Become better prepared for further IRS scrutiny on the horizon, including audits, litigation, and even criminal investigations by registering for this deep-dive program.

There are suspect items on tax returns that the IRS has identified as prime candidates for detailed review and document production – learn what will be scrutinized and how to prepare yourself, after attending this video webcast. You’ll be better prepared to appreciate client obligations before conflicts ripen and will improve your conflict resolution skills with the solutions taught by this exceptional faculty. You and your client cannot afford to be unprepared for an IRS tax controversy and the practical guidance shared during this program will be your ultimate resource on IRS controversies. Our two nationally recognized tax experts will guide you through:

IRS Large Business and International Compliance Campaigns

• Taxable Asset Transactions—Matching Buyers and Sellers
• Tax Cuts and Jobs Act of 2017 Campaign
• Financial Service Entities Engaged in a U.S. Trade or Business Campaign
• U.S. Territories—Erroneous Refundable Credits and Individuals Claiming Income Tax Residence in Puerto Rico
• Virtual Currency Taxation and Compliance
• Corporate Direct Foreign Tax Credits
• Expatriation of Individuals
• FIRPTA Reporting Compliance for Non-resident Aliens
• Related Party Transactions Campaign

Global High Wealth Group

• The “Revived Global High Wealth Group”—What to Expect

High Net Worth Non-filers and Forms 3520/3520-A Non-Compliance

• Repatriation of Foreign Earnings and Profits and Related Areas
• Dual Residency Issues

Handling Audits Before the IRS Examination Division

• Responding to IRS Requests for Information—-Circular 230 Rules
• Information Requests and Summons, Including John Doe Summons

Advising Clients in Sensitive IRS Audits and Examinations; Assessing Risks

• Privileges and Ethical Considerations

Speakers:

• Megan L. Brackney, Esq., Kostelanetz & Fink
• Jerald David August, Esq., Fox Rothschild LLP

Click here for more information and to register.