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Estate and Gift Tax Audits: Transfers, Valuation of Assets, Formula Clauses, GRATs, Forms 3520 and 3520-A, Penalties

A live 90-minute CLE/CPE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Tuesday, December 17, 2024

1:00pm-2:30pm EST, 10:00am-11:30am PST

Early Registration Discount Deadline, Friday, November 22, 2024

or call 1-800-926-7926

This CLE/CPE course will provide trust and estate attorneys with an in-depth analysis of the processes and strategies for handling estate and gift tax audits, recent case law, and IRS developments. The panel will discuss key IRS audit triggers, issues stemming from hard to value asset transfers, formula clauses, and preparing tax returns. The panel will also discuss challenges with GRATs and Forms 3520 and 3520-A and offer strategies for avoiding penalties.

Description

The IRS has ramped up audits for estate and gift tax returns at a higher rate than income tax returns. IRS audits of estate tax and gift tax returns and audits relating to the failure to file such returns often involve complex legal and factual issues.

When an estate or gift tax return is chosen for an IRS examination and audit, it is a time-consuming and costly process. Trust and estate counsel representing clients faced with an estate or gift tax audit must understand what the IRS is looking for, how a return is selected for audit, what documentation is needed, necessary procedural requirements and available options, and what to expect as part of a settlement. Understanding these steps is essential to successfully concluding an audit.

In addition, attorneys must recognize potential audit risks associated with specific estate planning strategies and related issues, such as transfers of hard to value assets, formula clauses, and the use of GRATs, Forms 3520 and 3520-A, and other items.

Listen as our panel discusses key IRS audit triggers, issues stemming from transfers of hard to value assets, formula clauses, and preparing tax returns. The panel will also discuss the challenges of GRATs and Forms 3520 and 3520-A and offer strategies for defending against audits and avoiding penalties.

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Outline

  1. Issues to expect
  2. Avoiding audit triggers
  3. Protecting the burden of proof
  4. Extending the statute
  5. The appeals process
  6. The current state of the IRS initiative

Benefits

The panel will discuss these and other key issues:

  • What are the hot issues that trigger estate and gift tax audits?
  • Complying with the all-important adequate disclosure requirements with gift tax returns
  • What are the most common estate and gift tax audit triggers?
  • How to lessen the chances of being selected for a gift or estate return audit
  • What are the timelines, processes, and deadlines involved in an estate and gift tax audit?
  • When to permit the extension of the statute of limitations with gift tax audits
  • What challenges arise from the use of GRATs and other planning techniques?
  • How to complete Forms 3520 and 3520-A
  • How to best communicate with the IRS

Faculty

Cohen-Kurzrock, Benjamin
Benjamin A. Cohen-Kurzrock, JD, CPA

Attorney
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian

Mr. Cohen-Kurzrock is a corporate and securities associate in the San Diego office.

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Lipoff, Lawrence
Lawrence M. Lipoff, CPA, TEP

Director
CohnReznick

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private...  |  Read More

Attend on December 17

Early Discount (through 11/22/24)

See NASBA details.

Cannot Attend December 17?

Early Discount (through 11/22/24)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video