IRS Promoter Investigations, Enforcement Actions, and Penalties: Syndicated Conservation Easements, Micro-Captives
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will guide tax professionals through new IRS enforcement actions focused on promoters of syndicated conservation easements and micro-captive arrangements. The panel will discuss recent IRS investigations of promoters of what they determine as abusive tax avoidance transactions, navigating the processes involved for examinations, new procedures of the IRS Office of Promoter Investigation, penalties, and key strategies for tax professionals. The panel will also discuss structuring micro-captives and conservation easement transactions to minimize IRS assessments and audits.
Outline
- IRS Office of Promoter Investigations
- Key items of focus for promoter investigations
- Syndicated conservation easements
- Micro-captive arrangements
- Other areas of IRS focus
- Avoiding or minimizing examination and penalties
- Best practices for tax professionals
Benefits
The panel will review these and other key issues:
- Overview of new IRS enforcement initiatives aimed at promoters of abusive tax avoidance transactions
- Key considerations and issues for fund managers and advisers
- Applicable rules and strategies to avoid IRS scrutiny for syndicated conservation easements
- Rules and planning to avoid IRS scrutiny for micro-captive arrangements
- Managing tax audits and collection cases
- Avoiding or minimizing penalties
Faculty
Sandra R. Brown
Principal
Hochman Salkin Toscher Perez
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations,... | Read More
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.
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Lois E. Deitrich
Acting Director, Office of Promoter Investigations
Internal Revenue Service
Ms. Deitrich has 20 years of experience with the IRS, having begun her career as a revenue officer in 2001. Prior to... | Read More
Ms. Deitrich has 20 years of experience with the IRS, having begun her career as a revenue officer in 2001. Prior to her current appointment, she was the director of the southwest area of SB/SE, overseeing abusive transaction investigations. Ms. Deitrich has also previously served as director of Exam Case Selection and Exam Quality and Technical Support.
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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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