High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide counsel and tax advisers with guidance on available options for handling high income non-filers and navigating IRS collection issues. The panel will discuss recent IRS enforcement actions for high income taxpayers, voluntary disclosure options, current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.
Outline
- Recent IR-2020-34 and challenges for high income non-filers
- IRS enforced collection process
- Voluntary disclosure
- Collection alternatives
- Criminal prosecution
Benefits
The panel will review these and other key issues:
- What are the key challenges in representing high income non-filers?
- What are the IRS penalty structures and pitfalls to avoid as applied to high income non-filers?
- What is the correspondence chain leading up to enforced collection action by the IRS?
- What are the remedies and relief provisions to challenge or mitigate a tax lien?
Faculty
Dennis L. Perez
Principal
Hochman Salkin Toscher Perez
Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax... | Read More
Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. He was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. Mr. Perez is a Certified Tax Specialist, California State Bar Board of Certification and is also a Fellow of the American College of Tax Counsel. He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. He is a co-author of the BNA Portfolio, Tax Crimes, has served as the Chair of the Los Angeles Lawyer Magazine Editorial Board and is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award for outstanding service to the Los Angeles Lawyer Magazine. He is past Chair of the Tax Procedure and Litigation Committees of the Taxation Sections of the State Bar of California and the Los Angeles County Bar Association. Mr. Perez is past President of the Alumni Board for the UCLA School of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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Steven (Steve) Toscher
Managing Principal
Hochman Salkin Toscher Perez
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions... | Read More
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.
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