3720 Tax Shelter Enforcement: Options for Taxpayers and Counsel
Price: $ 119.00 (USD)
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You will receive 1.75 credits (CE) upon completion of this course.
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Course Description
Private practice tax attorneys and representatives from the IRS, including the chief counsel, face off in a detailed discussion of IRS enforcement efforts in the tax shelter arena. The panelists discuss general aspects of global settlement initiatives as well as specific initiatives, including those for Son of Boss transactions and non-economic residual interest (NERI) securities. They also touch upon topics such as designating cases for litigation, penalty administration, and the fast-track appeals process.
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Course Outline
Tax Shelter Enforcement: Options for Taxpayers and Counsel
I. Evolution of Tax Shelters and Enforcement
A. Introduction
B. Historical Tax Shelter Examples
C. What Is a Tax Shelter?
D. Government Response
E. Tax Shelter Opinions
F. Tax Reform Act of 1986
G. New Tax Shelters
H. Long Term Capital Case
II. Recent Enforcement Efforts
A. NERI Settlement
B. “Son of Boss” Settlement
C. Tax Accrual Workpapers
D. Other IRS Initiatives
III. Global Resolutions
A. Speaker Introductions
B. Overview
C. Government Perspective
1. Why Do Global Resolutions?
2. The Right Balance
3. Three Characteristics
4. Tension Between Appeals and Global Resolutions
5. Settlement Initiative Guidelines
6. Successful Initiative: Son of Boss
7. Audit Lottery Players
8. Looking Forward
D. Private Perspective
1. What Is a Successful Settlement Initiative?
2. Factors Contributing to Success
IV. Chief Counsel’s Involvement in Enforcement
A. A True Partnership
B. Examination
C. Dealing With Resistance
D. Designating Cases for Litigation
E. The Designation Process
F. Statutory Notice of Deficiency
G. Penalty Administration
H. Clarifying IRS Stance on Penalties
V. Fast-Track Appeals
A. Concerns About Fast-Track Process
B. Be Cautious
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I. Evolution of Tax Shelters and Enforcement
A. Introduction
B. Historical Tax Shelter Examples
C. What Is a Tax Shelter?
D. Government Response
E. Tax Shelter Opinions
F. Tax Reform Act of 1986
G. New Tax Shelters
H. Long Term Capital Case
II. Recent Enforcement Efforts
A. NERI Settlement
B. “Son of Boss” Settlement
C. Tax Accrual Workpapers
D. Other IRS Initiatives
III. Global Resolutions
A. Speaker Introductions
B. Overview
C. Government Perspective
1. Why Do Global Resolutions?
2. The Right Balance
3. Three Characteristics
4. Tension Between Appeals and Global Resolutions
5. Settlement Initiative Guidelines
6. Successful Initiative: Son of Boss
7. Audit Lottery Players
8. Looking Forward
D. Private Perspective
1. What Is a Successful Settlement Initiative?
2. Factors Contributing to Success
IV. Chief Counsel’s Involvement in Enforcement
A. A True Partnership
B. Examination
C. Dealing With Resistance
D. Designating Cases for Litigation
E. The Designation Process
F. Statutory Notice of Deficiency
G. Penalty Administration
H. Clarifying IRS Stance on Penalties
V. Fast-Track Appeals
A. Concerns About Fast-Track Process
B. Be Cautious
AfterWordsSM
More Information
| Language | English |
| Course Length | 1.78 hours |
| Duration of Access | for 3 months from day of enrollment |
| Continuing Education Credits | 1.75 |
| Instructor | N. Jerold Cohen, Miriam L. Fisher, David I. Kempler, John C. Klotsche, Donald L. Korb, Charles P. Rettig, Donald T. Rocen |
| Vendor | Cognistar (Read more about Cognistar accreditation.) |
| Course Certification | CLE credit available, see details for each course for states where available |
| Prerequisites/Audience | intended for attorneys and law students |
| Requirements/Materials Included | computer with Internet access |
Price: $ 119.00 (USD)
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