This roundtable will discuss the current status of the CIC Services case, the arguments that each side and amici presented, and thoughts on the Supreme Court’s upcoming ruling. The discussion will also provide helpful background on the Anti-Injunction Act, historical developments with respect to the...
This roundtable will discuss the status of Revenue Procedure 94-69. In August, the LB&I announced that it is considering rescinding Rev. Proc. 94-69. Rev. Proc. 94-69 provides special procedures for taxpayers that are subject to the former Coordinated Examination Program to show additional tax due...
This roundtable will discuss recent developments in FBAR Litigation and Enforcement. Topics will include the current state of the willfulness standard pursuant to recent cases, the current state of multiple non-willful penalties per year, and the Bernstein Fifth Amendment FBAR litigation. About the Speakers Thomas...
This roundtable will discuss the current state of various criminal tax matters and provide an update on recent developments with respect to IRS enforcement priorities. The panelists will also give a brief overview of the structure and workings of the IRS’s Criminal Investigation division. Registration...
Young Tax Lawyers Series: Choose Your Own Adventure – Careers in Tax Law Ahead of TIP, join the FBA Section on Taxation on February 11th at 5 pm to hear from a panel of attorneys with experience working at law firms, accounting firms, the IRS...
This roundtable will discuss recent and ongoing common tax collection matters, including collection alternatives under IR-2020-248 and changes to collection procedures under the People First Initiative, including passport revocation certifications. The panel will also discuss unique challenges that occur with respect to international information return reporting...
Join the Section on Taxation for the 45th Annual Tax Law Conference on March 3-5, 2021. This newly formatted three-day virtual program will offer the same great content online. Examine important tax developments and emerging policy issues in over 30 educational sessions featuring notable speakers...
Thursday, April 8 | 10 AM PT / 1 PM ET* Cryptocurrency is a hot-button issue for IRS enforcement. Cryptocurrency presents practitioners with accounting and reporting challenges. Further, a tool for illicit conduct, cryptocurrency presents potential criminal concerns for every client. This presentation outlines civil...
This roundtable will discuss recent and ongoing IRS tax enforcement measures targeted towards high net worth individuals, including the Global High-Wealth Audits campaign. Attendees will hear about where the IRS is focusing its resources, coordination between civil and criminal investigations, potential effects of the Biden...
The FBA Section on Taxation offers another virtual seminar on topics of interest to the insurance industry. The seminar will continue its tradition of providing a forum for a robust dialogue between the insurance industry, tax practitioners and government sector professionals. The program will be...
This roundtable will discuss the Biden Administration's political appointment process and Senate confirmation process, and will provide commentary on the Transition. About the Presenter Andrew Strelka is currently the Senior Tax Counsel in the Biden-Harris White House. In 2008, Strelka began his legal career at...
Tuesday, June 22, 2021 | 12:30 PM ET Come join the FBA Tax Section for "The Role of Nutrition for Busy Lawyers (and Everyone)” hosted by the Health & Wellness Committee on June 22, 2021 at 12:30 pm ET! This panel will address the importance of nutrition...