2023 IRS Enforcement Update: Key Areas of Focus for Examinations, Audits, and Criminal Cases
Abusive Tax Avoidance Transactions, Crypto-Related Audits, Criminal Digital Asset Cases, Transfer Pricing, High-Income Taxpayers
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide guidance to tax professionals on the 2023 IRS enforcement initiatives and key issues for taxpayers. The panel will discuss recent IRS investigations, abusive tax avoidance transactions, increased crypto-related audits, criminal digital asset cases, transfer pricing, and examinations of high-income taxpayers. The panel will also offer tactics for navigating the processes involved for examinations, penalties, and criminal cases.
Outline
- High-income taxpayers
- Transfer pricing examinations
- Crypto and other digital asset transactions
- Abusive tax avoidance transactions
- Other IRS areas of focus and key considerations for taxpayers
Benefits
The panel will discuss these and other key issues:
- What have been the key areas of focus in recent IRS investigations and tax disputes?
- What tax reporting and compliance issues arise for high-income taxpayers?
- What is the IRS' current outlook and treatment of crypto transactions and reporting?
- What transactions have the IRS considered to be abusive tax avoidance transactions?
- How to navigate IRS investigations and avoid or limit penalties or criminal liability
Faculty
Laura L. Gavioli
Partner
Alston & Bird
Ms. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an... | Read More
Ms. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, she is known for achieving practical, client-driven goals when defending against IRS inquiries. Ms. Gavioli has represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the U.S. and advises clients on the IRS Whistleblower Program. She attained taxpayer victories in civil tax cases in U.S. Tax Court and federal district courts, eliminating IRS penalties.
CloseMatthew D. Lee
Partner
Fox Rothschild
Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white... | Read More
Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense, federal tax controversies, financial institution regulatory compliance, and complex civil litigation. He has significant experience in conducting corporate internal investigations and advising banks and financial institutions as to compliance issues involving FATCA, the Bank Secrecy Act, the USA Patriot Act, anti-money laundering laws and regulations, and economic sanctions. He also represents financial institutions in enforcement proceedings brought by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN).
CloseEric M. Nemeth
Partner
Varnum
Mr. Nemeth is a partner and leads the firm’s Tax Planning, Compliance and Litigation Practice Team. He has... | Read More
Mr. Nemeth is a partner and leads the firm’s Tax Planning, Compliance and Litigation Practice Team. He has extensive experience in tax law with a focus on all aspects of related civil and criminal law, as well as complex financial investigative and litigation matters.
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