SANDRA BROWN to Speak at Upcoming Webinar on Practitioners Guide to IRS High Income/High Wealth Audits
We are pleased to announce that Sandra Brown along with John Colvin, Monique (Mimi) R. Gabel, Sarah E. Paul and Cliff Scherwinski will be speaking at the upcoming ABA Section of Real Property, Trust & Estate Law eCLE webinar, “Practitioners Guide to IRS High Income/High Wealth Audits” on Wednesday, September 15, 2021, 10:00 a.m. – 11:30 a.m. (PST) | 1:00 p.m. – 2:30 p.m. (EST).
As part of the IRS’s renewed attention to the IRS Global High Wealth initiative and narrowing the tax gap, the IRS has increased its focus on high income non-filers and high wealth taxpayer audits. The IRS’s renewed emphasis on high income non-filers and high wealth taxpayers is a broad focus that manifests itself through the Global High Wealth program, various campaigns and directives as well as normal Exam workloads. This new focus has resulted in parallel civil and criminal investigations in several priority areas. This esteemed panel of current IRS officials, former DOJ Tax attorneys and private practice attorneys will discuss these audits, including the following:
Ethical issues for tax practitioners, including representing multiple taxpayers in Exam and the potential impact of a practitioner’s prior role in structuring or promoting transactions subject to Exam scrutiny;
Partnership tax audits under the BBA and IRS focus on pass-through tax issues, such as losses and distribution in excess of basis, sale of partnership interests, and self-employment taxes at the partner level;
Other issues based areas including micro-captives, conservation easements, private foundations and Malta pension; and
Criminal tax issues to consider before and during the audit process.
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