Anatomy of an IRS Criminal Investigation

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Robert Brennan

Robert P Brennan CPA, LLC

Wednesday, December 23, 2020 | 10:00 AM EST

  • CPA
  • EA
  • CTEC
  • AFSP

Credits: 4 CPE | 4 CE


Subject Area


Webinar Qualifies For

4 CPE credit of Taxes for all CPAs

4 CE credit of Federal Tax for Maryland Tax Preparers

4 CE credit of Federal Tax for Oregon Tax Preparers

4 CE credit of Federal Tax Subjects for California Tax Professionals (CTEC Approved - 6273)

4 CE credit of Federal Tax for Enrolled Agents ( IRS Approved : GEHNZ )

4 General Educational credit for Tax Professionals / Bookkeepers / Accountants

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Course Description

When the Internal Revenue Service believes you have committed a tax crime, they may launch a criminal investigation against you. Typically, the IRS Special Agents will be tasked with conducting the investigation into your background, finances, and tax history to assess the damage. In recent years, with the service making foreign accounts compliance a key enforcement priority, taxpayers who have not properly disclosed offshore accounts, assets, investments and income are at a high risk. What would happen once the case is assigned to IRS Criminal Investigation Division? How does the division determine who should be prosecuted? The presenter will provide a bird’s eye view on the overall process. 

Highlights of the webinar :

  • How an IRS Criminal Investigation is originated.
  • Do you file an Amended Return during a Criminal Investigation of a Taxpayer?
  • How a Normal Civil Audit Becomes a Criminal Referral to the Criminal Investigation Division.
  • What is the IRS Criminal Investigation Division looking for to pursue a Case?
  • The Difference between Intent and a Mistake
  • A review of the IRM Part 9 that covers IRS Criminal Investigations.
  • What Techniques IRS Special Agents use to Interview “Targets” of their Investigations, Surprise Home Visits, etc.
  • Investigative Techniques to support their Criminal Referral to Dept of Justice, i.e. Direct and Indirect Methods of Proof.
  • Common defenses against IRS Accusations of Criminal Tax Fraud.
  • The difference between the Civil and Criminal Tax Computations.
  • Clients Rights to Conferences with the Government before Indictment.
  • The Role of the IRS Experts at Trial
  • The Role of the Defense Expert at Trial and the preparation for Effective Testimony
  • Computation of Tax Loss
  • The difference between Restitution, Fines and Civil Tax Due
  • Settling the Civil Tax Due After the Trial, regardless of Guilt or Innocence.
  • The Application of Penalties, specifically Fraud, Negligence and Substantial Understatement Penalties.
  • Statute of Limitations on IRS Fraud Cases
  • Review of Real-Life Fraud Cases and the mistakes made on both the Government and the Defense Side.
  • Current Trends in IRS Criminal Investigation

Learning Objectives

  • To explore Internal guidelines of IRS Criminal Investigation Division
  • To recognize how the criminal investigation begins for the division until it reaches in an indictment or declination to prosecute.
  • To identify methods used by IRS Criminal Investigators to determine if there was a Criminal Tax Fraud - covers Interview techniques, Method of proof of fraud, Tax loss computation for criminal purposes, Civil tax due and owing
  • To recall Taxpayer Rights during the investigation
  • To explore how accountant can be a fact witness or a witness for the client

Who Should Attend?

  • Tax Attorney
  • Tax Practitioners
  • Accountant
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  • Tax Pros
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  • Senior Accountant
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