7:30 – 8:30 am:

Registration & Breakfast

8:30 – 8:35 am:

Opening Remarks / Housekeeping Items

8:35 – 10:00 am:

IRS Update

Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years of pandemic and the fallout afterward, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax and yet help struggling taxpayers. These panel interviews provide us with an update on new developments at the IRS.

IRS Collection: Mary Beth Murphy, IRS Territory Manager, North Atlantic Territory

• Interviewed by: Eric Green, Green & Sklarz LLC, New Haven, CT

Criminal Investigations: Shea Jones, Deputy Chief, IRS Criminal Investigation, Washington, DC

• Interviewed by: Kathy Enstrom, Moore Tax Law Firm, Chicago, IL

Appeals: Elizabeth P. Askey, Chief, Independent Office of Appeals, Washington, DC

• Interviewed by: Jeffrey Sklarz, Esq., Green & Sklarz LLC, New Haven, CT

10:00 – 10:15 am:

Break

10:15 – 11:05 am:

Enforcement Trends: What’s Hot and What’s Not

Following the Covid pandemic and the programs instituted by Congress we are about to enter a new era of tax enforcement, including Employee Retention Credits, Crypto Currency, Payroll Tax Debts, and much more.  Join our panelists for a discussion of the changing tax enforcement landscape as it relates to examinations, collection and criminal investigations.

Moderator:   

• Michelle Ferreira, Esq. Greenberg Traurig LLP, San Francisco, CA

Panelists:    

• James Grimaldi, Esq., Citrin Cooperman, New York, NY
• Christopher Ferguson, Esq., Kostelanetz, LLP, New York, NY
• Miri Forster, Esq., Eisner Advisory Group LLC, New York, NY

11:05 – 12:00 pm:

How to File a Refund Claim

Maybe it is a mistake on a prior return, the taxpayer needs to challenge a bad tax assessment, or a preparer who disagrees with preparer penalties assessed against them by the IRS.  In all of these cases, paying some or all of the assessment and filing a refund claim is a legitimate way to reopen and have these issues looked at.  This panel will review the procedures for filing a refund claim, under what circumstances the entire tax must be paid versus just a percentage, and what the process looks like for challenging the IRS decision in court.

Moderator:  

• Jeffrey Sklarz, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:       

• David Shuster, Esq., Marcum, LLP, New York, NY
• Walter Pagano, CPA, CFE, Eisner Advisory Group LLC, New York, NY

12:00 – 12:45 pm:

Lunch

12:45 – 1:45 pm:

Creative Collection Alternatives

Issuance of collection notices have resumed in full force and the IRS has increased its efforts to pursue high net worth taxpayers with outstanding tax debt. One of the most common questions raised by taxpayers faced with potential or assessed tax liabilities is: What are my options? A simple question that requires the tax professional to explain the numerous and often complex paths to resolving federal liabilities. While navigating the numerous options, taxpayers must address ever-increasing enforcement actions, including, but not limited to, the filing of Notices of Federal Tax Lien, levies and wage garnishments, responsible person investigations, and nominee or alter ego liens. This panel reviews a taxpayer’s options, best practices, and tips of the trade.

Moderator:   

• Eric L. Green, Esq., Green & Sklarz, LLC, New Haven, CT

Panelists:    

• Darren Guillot, alliantGroup, Washington, DC
• Beverly Winstead, Esq., Principal, Law Office of Beverly Winstead, Baltimore, MD
• Amanda Evans, EA, Green & Sklarz LLC, New Haven, CT

1:45 – 2:45 pm:

ETHICS: Handling Employee Retention Credit Audits and Investigations: Coloring in the Lines

Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. To address questionable claims, the IRS recently announced a Voluntary Withdrawal and Voluntary Disclosure Program to give taxpayers with possibly ineligible claims an opportunity to come forward, cooperate with the IRS, and, in return, minimize their financial exposure including penalties. The IRS is also aggressively auditing ERC claims and pursuing penalties and criminal prosecutions for ERC related abusive schemes and fraud. This panel of experienced practitioners discusses the IRS’s targeted enforcement efforts, explains how to spot red flags indicating abuse of the ERC, describes the penalties that apply to taxpayers, promoters, and practitioners for erroneously claiming ERC credits, and addresses the filing of the corresponding wage reduction on an income tax return.

Moderator:   

• Damon Rowe, Esq, CPA, Meadows Collier Cousins Crouch Reed & Ungerman, Dallas, TX

Panelists:    

• Eric Hylton, National Director, alliantGroup, Washington, DC
• Daniel Mayo, Esq., Withum, Smith & Brown, PC, Red Bank, NJ
• Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ

2:45 – 3:00 pm:

Break & Snack

3:00 – 4:00 pm:

Out of the Frying Pan and Into the Fire: What Makes a Case Move from the Civil Function to IRS Criminal Investigation

So, the client and their tax professional might have become a bit overzealous in their planning and now the IRS is looking at the positions taken on the return.  What makes a case move from the civil side of the IRS to Criminal Investigation?  Our panel of current and former criminal tax experts will walk you through the government review and weighing of the factors it goes through in making that determination.

Moderator:     

• Lisa Perkins, Esq., Green & Sklarz LLC, West Hartford, CT

Panelists:

• Carolyn Schenck, National Fraud Counsel and Assistant Division Counsel (International), IRS Office of Chief Counsel, Washington, DC
• Damon Rowe, Esq., CPA, Meadows Collier Cousins Crouch Reed & Ungerman, Dallas, TX
• Shea Jones, Deputy Chief, IRS Criminal Investigation, Washington, DC

4:00 – 5:00 pm:

High Net Worth Taxpayer Audits: The Tax Man Cometh

This panel will review the hot button topics when comes to IRS examinations of high net worth individuals and their businesses.  The panel will include hot button topics with S Corporations and Partnership returns, high income non-filers, reasonable compensation and basis issues.          

Moderator:   

• Robert Day, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:  

• Michael D’Addio, Esq., Marcum LLP, New Haven, CT
• Paul Hamann, President, RCReports
• Barbara Kaplan, Esq., Greenberg Traurig LLP, New York, NY