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Showing sessions 41 - 41 of (41) TOTAL sessions
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Event : ABATX40


Session : ABATX18145
Civil & Criminal Tax Penalties
Conference : 2018 Fall Tax Meeting
Speaker(s) :
Download Format(s) :
MP3
$45.00


  • Chair: Niles A. Elber, Caplin & Drysdale, Washington, DC
  • Reports of Subcommittees on Important Developments. Important Developments (Civil) – Sara G. Neill and Michelle F. Schwerin, Capes Sokol Goodman Sarachan PC, St. Louis, MO; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA and Claire Taylor, Colvin & Hallett, Seattle, WA; International Tax Enforcement – Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC and Joseph M. Erwin, Dallas, TX; IRS Investigations and Practices – Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX and Eric L. Green, Green & Sklarz LLC, New Haven, CT; Legislative and Administrative Developments – Brian C. McManus, Latham & Watkins LLP, Boston, MA and Robert J. Kovacev, Steptoe & Johnson, Washington, DC; Monetary Violations and Forfeitures – Peter D. Hardy, Ballard Spahr LLP, Philadelphia, PA; Offshore Compliance and Enforcement – Zhanna A. Ziering, Caplin & Drysdale Chtd., New York, NY and Michael Sardar, Kostelanetz & Fink LLP, New York, NY; Sentencing Guidelines – Matthew C. Hicks, Caplin & Drysdale Chtd., Washington, DC and Jeffrey A. Neiman, Marcus Neiman & Rashbaum, Fort Lauderdale, FL
  • It’s All About the Penalties. When it comes down to it, the decision of whether to settle with the IRS often depends on the penalties imposed. Knowing what penalties there are and what the IRS must do to successfully impose them is an extremely important part of representing taxpayers. This panel will survey the penalties that practitioners are most likely to run across and discuss: 1) the IRS process for considering and asserting penalties, 2) the implications of assessable versus non-assessable penalties and 3) taxpayer options for relief from or challenging penalties. The discussion will also touch on recent developments related to Section 6751 penalty approval and the IRS first time penalty abatement program. Moderator: Richard Pelak, Culp Elliott & Carpenter, Charlotte, NC Panelists: Robin L. Greenhouse, Acting Division Counsel, LB&I, IRS Office of Chief Counsel, Washington, DC; Frank Agostino, Agostino & Associates PC, Hackensack, NJ; Mary E. Wood, Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX
  • Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview. Should your client decide to answer the government’s questions, whether in response to a polite request by a Revenue Agent, an administrative summons, a grand jury subpoena, or a proffer, preparation is critical, because, let’s face it, a lot can go wrong. This panel of experienced tax litigators will discuss how they decide whether to let their clients talk and the strategy involved in those decisions. The panelists will offer practical tips for preparing your client for the government interview, handling the interview itself, and what to do if the interview goes “off the rails.” This is the second in a planned series of skills workshops. Moderator: Sara G. Neill, Capes Sokol Goodman Sarachan PC, St. Louis, MO Panelists: Larry A. Campagna, Chamberlain Hrdlicka, Houston, TX; Patricia A. Pileggi, Schiff Hardin LLP, New York, NY; Edward M. Robbins Jr., Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA
  • OVDP – End of an Era. Though its use by taxpayers has substantially dwindled in recent years, for nearly a decade, the Offshore Voluntary Disclosure Program was a major component of the IRS’s effort to bring US taxpayers into compliance with their offshore reporting obligations, and helped facilitate the return of billions of dollars to the tax base. Neither the IRS nor Department of Justice have given any indication that they have stopped searching for offshore tax cheats and no doubt there are many individuals who still need to come in from the cold. But, without the OVDP, what advice can the practitioner provide? A panel of experienced lawyers and IRS officials will discuss this question and share their thoughts on how and whether a taxpayer can still disclose previously unreported offshore assets without serious risk of criminal prosecution or huge offshore penalties. Moderator: Niles A. Elber, Caplin & Drysdale Chtd., Washington, DC Panelists: Eric Hylton, Deputy Chief, IRS Criminal Investigations Division, Washington, DC; Daniel N. Price, Attorney, IRS Office of Chief Counsel (SB/ SE), Austin, TX; Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC; Brian C. McManus, Latham & Watkins LLP, Boston, MA



     


Showing sessions 41 - 41 of (41) TOTAL sessions
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