Stay updated on critical tax and ethics issues, including IRS changes, Supreme Court rulings, and strategies for high-net-worth client representation.
Many practitioners recognize that the IRS and various state taxing authorities view the administrative regulations as mandatory and binding. However, recent court cases, including the Supreme Court’s decision in Loper Bright et al., has changed the landscape. Further, with the increase in IRS funding and expected increase in high net worth audits, representing clients that have high net worths has become a more significant and more challenging process.
This program includes a discussion of timely tax and ethics issues that the tax practitioner needs to be made aware of. An update on ‘hot’ IRS practice, procedure and ethics issues, including the impact of the U.S. Supreme Court’s decision in Loper Bright; and ethical and practical blunders and mistakes practitioners should avoid.
Learning Objectives
- You will be able to recognize how to deal with high net worth audits and navigate the challenges associated with those audits; when an IRS regulation is binding and when the taxpayer’s ability to challenge the regulation.
- You will be able to explain what IRS regulations mean after Loper Bright.
- You will be able to review and spot ethical issues and concerns.
- You will be able to discuss how to plan for high net worth clients and family office planning.
Agenda
What Do IRS Regulations Mean After Loper Bright?
- Chevron and the History of Court’s Being Bound by IRS Regulations
- Judicial Deference to the IRS
- Current State of the Law
- Hot Issues
High Net Worth Audits
- What Are the Hot Issues
- How to Prepare for a High Net-Worth Audit
- Responding to IRS Requests for Information
- Valuation Issues
Employment Tax and Form 941 Audits
- Is the ERC the New Hot Issue?
- Addressing the Affirmative Tax Audit
- How to Negotiate an Interest-Free Investment
Hot Issues
- The Section 41 Research Credit
- Ethical Concerns
- Refund Claim Traps and What the Practitioner Should Be Concerned About
Speakers
Michael G. Goller,
Reinhart Boerner Van Deuren S.C.- Shareholder and chair of Reinhart Boerner Van Deuren S.C.’s tax practice
- Member of the firm’s litigation and corporate law practices
- His practice focuses on tax controversy, tax litigation, and tax planning
- The clients he represents include large, public corporations, mid-sized, privately held businesses and their owners
- He handles a wide variety of tax-related issues, including complex income and estate and gift tax controversies
- Represents clients involved in disputes with the IRS, the Department of Justice, and various other taxing authorities before the United States Tax Court, various federal district courts, the United States Court of Federal Claims, various state courts and the Seventh Circuit Court of Appeals
- As an experienced tax attorney and tax litigator, he assists his clients in navigating the challenges associated with complex federal and state tax audits, disputes, administrative appeals, trials and subsequent appeals
- Serves as a trusted advisor and legal strategist who is able to draw upon his vast knowledge and experience to offers unparalleled proficiency in his field, which is evidenced in his impressive track record of successfully trying cases to favorable settlements; clients appreciate that he has the personality of litigator with the expertise of a tax attorney and provides legal advice from this unique intersection
- J.D. degree, cum laude, Marquette University Law School; B.S. degree in accounting, Marquette University
Who Should Attend
This live webinar is designed for accountants, CPAs, CFOs, controllers, tax managers, tax preparers, presidents, vice presidents, bookkeepers, accounts payable professionals, finance directors.
