The number of tax penalties assessed by the Internal Revenue Service has increased dramatically over the past several years. For example, assessments of accuracy-related penalties against individuals and corporations rose from 59,708 in 2005 to 472,961 in 2010, a nearly 800% increase! At the same time, the Internal Revenue Service is focusing more than ever before on the conduct of professionals, through return preparer penalties, Circular 230 enforcement and even criminal prosecutions. Sophisticated and responsible practitioners engaged in tax planning or tax controversies must understand where the lines are drawn and consider application of penalties when appropriate. However, accounting and law school tax classes rarely focus on penalties, leaving practitioners to pick up the relevant standards and procedures from the trial and error of daily practice.
This one-day seminar is a unique opportunity to review the various tax penalties that can be imposed, the standards and transactions that can trigger penalties and sanctions, the procedures the Internal Revenue Service must follow to assess penalties and the defenses that can be asserted. We have assembled an expert faculty of experienced private practitioners and government representatives to explain how penalties work, why they are assessed and how you can protect yourself and your clients.
What you will learn
- Understand why penalties are assessed, which penalties apply to what types of conduct, and who can be subject to penalties, the taxpayer, the preparer, or both
- Explore the difference between professional ethical standards of conduct, Circular 230 standards and tax penalties
- Find out how certain you have to be before you can advise a client to take a tax position on a return
- Learn to recognize when you can rely on your client for information and when you have to dig deeper
- Examine situations where conduct is so egregious that it can trigger a fraud penalty
- Discover what turns a civil penalty case into a criminal tax prosecution
- Get tips on approaching tax situations that involve potentially criminal conduct
Who should attend
Law firm and accounting firm professionals who advise clients on structuring transactions and who represent clients in tax controversies; in-house tax professionals involved in tax planning, FIN 48 determinations and tax audits and appeals; and government agents and attorneys who want a primer on tax penalties and ethical standards.
PLI Group Discounts
Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact firstname.lastname@example.org or call (800) 260-4PLI.
PLI Can Arrange Group Viewing to Your Firm
Contact the Groupcasts Department via email at email@example.com for more details.
All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.