IRS Crackdown on Abusive Trust Arrangements: Taxation, Audit Triggers, Reporting, DNI, Foreign Trusts
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide guidance to trusts and estates attorneys and tax professionals on IRS enforcement actions and examinations focused on abusive trust arrangements. The panel will discuss key areas of focus by the IRS in examining trust arrangements and related transactions, taxation of trusts and audit triggers, reporting issues and potential civil and criminal penalties, distributable net income (DNI), foreign trust challenges, and other items that are prime targets for an IRS examination of certain trust arrangements.
Outline
- Applicable tax rules and trust structures
- IRS enforcement initiatives
- Trust filing requirements
- Domestic trusts
- Foreign trusts
- Best practices for estate planners and taxpayers
Benefits
The panel will discuss these and other key issues:
- What are the applicable tax rules and reporting obligations for domestic and foreign trusts?
- What are the areas of focus of the IRS regarding abusive trust arrangements and transactions?
- How can estate planners and taxpayers avoid potential audit triggers in trust structuring and transactions?
- What are the key provisions or modifications available for trust documents in light of the IRS crackdown on trust arrangements?
Faculty
Cliff A. Capdevielle
Director, Trusts and Estates Tax Services
MOBO Law
Mr. Capdevielle helps clients navigate the complex opportunities related to tax planning, business succession planning,... | Read More
Mr. Capdevielle helps clients navigate the complex opportunities related to tax planning, business succession planning, and estate planning, and seeks to maximize tax savings and reach their goals.
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Matthew L. Roberts, J.D., LL.M.
Partner
Gray Reed
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients... | Read More
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Mr. Roberts brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships and corporations.
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