Tax fraud, tax controversy focus of ABA conference Dec.6-8 in Las Vegas

Leading practitioners and professionals from across the country will discuss important developments for criminal tax fraud and tax controversy during the 34th Annual National Institute on Criminal Tax Fraud and the Seventh Annual National Institute on Tax Controversy in Las Vegas.

Program highlights include:

• “Criminal Tax Workshop” —This workshop will discuss strategies and techniques for handling sensitive civil examinations and criminal investigations, and defending a criminal prosecution. The workshop includes a “criminal tax toolkit” of practice tips prepared by experienced practitioners.

• “DOJ Criminal Roundtable” — Hear a roundtable discussion of hot topics, recent decisions, and enforcement priorities in criminal tax enforcement. The speakers are all current or former Department of Justice leaders and prosecutors.

• “IRS CI Roundtable” — The IRS Criminal Investigation Division is on the front line of criminal tax investigations. IRS CI representatives and practitioners will discuss the top priorities and future challenges in criminal tax enforcement.

• “Sentencing and Incarceration Considerations” — The panel will discuss considerations and a practical approach to criminal sentencing, including preparation of a sentencing memorandum, recent increase in sentences for offshore crimes, restitution and forfeiture, calculation of tax loss and relevant conduct.

• “Offshore Investigations: What Now?” — The issues keep coming: What should recalcitrant accountholders do now? What are the issues in penalty enforcement litigation? How much information does the government have and what will future prosecutions look like? Will we start to see prosecutions under Section 7212(a)?

• “Collection: New IRS Techniques and Key Taxpayer Strategies” — IRS collection has recently implemented even more tools to encourage payment of taxes owed. Hear leading collection professionals discuss mitigation techniques when your client is faced with passport restrictions, private debt collectors, repeat employment tax liabilities, penalty assessments and more. Learn how Taxpayer Bill of Rights (TBOR II) can be used in the Collection Dues Process (CDP), when the Fair Debt Collection Practices Act can be applied to tax collections, and distinguish when administrative v. judicial solutions are most appropriate.

• “Marijuana: Ethical and Legal Issues in Representing Taxpayers” —  IRS examinations of taxpayers involved in the cannabis industry are now becoming more common as numerous states legalize medical/retail sales. Should your cannabis or bitcoin client consider taking the Fifth during an IRS examination? A distinguished panel will discuss the opportunities and pitfalls for tax professionals working with clients who are involved in the state legal cannabis industry including discussions regarding professional risks and responsibilities arising from representation of medical marijuana/retail businesses as well as current federal tax issues involving the cannabis industry.