This program will discuss best practices when representing a Taxpayer that has committed fraud on his or her tax return. Fraud may be underreporting income, excessive business deductions, concealing assets – both domestic and international assets, structuring, misclassification of employees, failure to file correct 941s or Trust Fund issues, and many other scenarios that could lead to a civil penalty, or worse, criminal charges.
Webinar Objectives
This program will provide insight and tools to assist your client navigate the delicate nature of audits that have potential fraud exposure. You will learn what disclosure to affirmatively make, and those disclosure to try and avoid. You will learn what the IRS looks for in determining whether fraud is present and how to mitigate fraud to hopefully keep the audit civil, and not criminal. We will discuss how to respond to an IRS Summons for documentation and interview of the taxpayer. And we will learn best practices when your client’s case is referred for criminal prosecution.
Webinar Highlights
- How to determine if Fraud is present – ask the tough question to the client.
- How to tell if the IRS is aware of fraud.
- Tools to mitigate the damage from a fraudulent tax return.
- Civil consequences of a fraudulent return.
- Criminal consequences of a fraudulent return.
- How to correct a fraudulent tax return.
Who Should Attend
- Accountants
- Tax preparers
- CFOs
- Financial compliance professionals
- Lawyers
Client Testimonial (MarcT)
This was my second tax law related seminar (one on civil tax fraud and the other on penalty abatement requests) presented by attorney Adam Fayne. He explains the complex clearly (e.g., the elements of civil tax fraud, defenses, and the IRS’s burden of proof), he understands what he is talking about (e.g., frequently providing numerous real-world examples from his own tax law practice), and he has depth of knowledge of tax law (which is rare for such a vast topic). He does the little things that a seminar attendee would appreciate. His slides seen throughout the seminar are a helpful and concise resource for later reference. Also, Mr. Fayne took the time at the beginning to let us know about a recent US Tax Court decision decided days before the seminar that provides potential refund opportunities to taxpayers inappropriately assessed “Form 5471 penalties.” Similarly, he mentioned and cited on slides, when relevant, citations to the tax code, the Internal Revenue Manual, and case law. I’d give both seminars I have attended my highest recommendation to experienced tax practitioners, as well as those new to that practice.
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