Taxpayer Defense: How to Represent Clients Facing Audit and Frâud Charges

Frâud may be underreporting income, excessive business deductions, concealing assets – both domestic and international assets, structuring, misclassification of employees, failure to file correct 941s or Trust Fund issues. Our expert speaker will discuss the implications of the civil fraud penalty which may be as high as 75% of the tax understatement. This webinar will provide an overview of both civil and criminal tax Frâud. You will learn how to represent your client during audits where Frâud is present, in an effort to keep the audit civil without referral to the Department of Justice for indictment. As part of this discussion, we will provide you with the solutions necessary to try and negotiate the lowest possible penalty.

Webinar Objectives

This webinar will provide you with the tools necessary to best represent taxpayers who are under audit and have committed Frâud. You will understand the terminology in these Frâud audits and understand the various options and paths forward for your client.

Webinar Highlights

• The difference between civil Frâud and criminal charges.
• The process the IRS uses to determine whether to keep a case civil or criminal.
• The various methods to try and negotiate that the case remain civil, and not criminal.
• The applicable penalties in civil tax Frâud cases.
• How to negotiate the reduction of the civil tax Frâud penalty.

Who Should Attend

Accountants, tax preparers, CFOs, financial compliance professionals, and lawyers

Client Testimonial (MarcT)

This was my second tax law related seminar (one on civil tax fraud and the other on penalty abatement requests) presented by attorney Adam Fayne. He explains the complex clearly (e.g., the elements of civil tax fraud, defenses, and the IRS’s burden of proof), he understands what he is talking about (e.g., frequently providing numerous real-world examples from his own tax law practice), and he has depth of knowledge of tax law (which is rare for such a vast topic). He does the little things that a seminar attendee would appreciate. His slides seen throughout the seminar are a helpful and concise resource for later reference. Also, Mr. Fayne  took the time at the beginning to let us know about a recent US Tax Court decision decided days before the seminar that provides potential refund opportunities to taxpayers inappropriately assessed “Form 5471 penalties.” Similarly, he mentioned and cited on slides, when relevant, citations to the tax code, the  Internal Revenue Manual, and case law. I’d give both seminars I have attended my highest recommendation to experienced tax practitioners, as well as those new to that practice.