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Advance IRS Learning: Multiyear Non-filing, Criminal Investigation, Voluntary Disclosure, Whistleblower Claims Etc.

Robert Brennan

Robert P Brennan CPA, LLC

  • AFSP
  • CPA (US)
  • EA
  • Tax Preparer
  • CTEC

Published: June, 2021

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Before starting this self study program, please go through the instructional document.

Overview

  • What is the Current Status on non-Filers and What is the IRS doing About it?
    5 mins
  • what is the IRS Looking for in A non-filer Investigation?
    29 mins
  • What is the Difference between a filed return and a Substitute for Return (SFR)? the Impact of Statute of Limitations.
    46 mins
  • How to Determine whether You (the Accountant) will be a Target of the Investigation along with Your Client!
    73 mins
  • Tax Crimes and Defenses
    88 mins
  • What is the TAX GAP and why is it a Driving Force Behind the Whistleblower Program.
    109 mins
  • What is Next, After the Claim Submission.
    125 mins
  • Should an Attorney be part of the Whistleblower Claim Team?
    138 mins
  • What is s "Quite Disclosure" and the Risk Associated
    171 mins

Course Description

Having special requirements for the IRS cases call for special training for tax professionals. This unique value webinar deals with some of the most complex cases presented by the IRS. They are multiple years of not filed tax returns, finding a tax return you prepared under criminal investigation, IRS whistleblower claims, and IRS voluntary disclosure programs. This webinar covers all these topics with a special focus providing a session on each of them. The key areas covered in each session are explained in detail below. 


Are tax problems keeping your clients awake at night? Are your clients afraid that they could lose their home, business, or other assets?

Delinquent returns are often more closely examined and scrutinized by the IRS, requiring that much more care and accuracy to avoid audits. Clients often require an experienced attorney that can provide the expertise needed alongside the protection of the attorney-client privilege — a vital asset if you feel that you’re at risk for prosecution. Delinquent taxes, if handled in the wrong way, drastically increase the chance of criminal prosecution or enforced collection activity.

As Per the Taxpayer Inspector General for Tax Administration (TIGTA) Non-Filers for 2011 - 2013 accounted for $39 Billion in Unpaid Income Taxes Due the Government. Learn what the IRS is currently doing to address this problem.

This session of this online CPE/CE course will cover:

  • How far back a taxpayer should file to be in compliance with the Internal Revenue Service.
  • Identify how Non-Filers are not Equal
  • How the Accountant should approach a Non-Filer situation regarding the amount of Years Past Due?
  • Filing Status on the Delinquent Returns.
  • Statute of Expiration Implications.
  • IRS filing of Substitute for Returns on behalf of the Taxpayer.

IRS Criminal Investigation serves the American public by investigating potential criminal violations of the Internal Revenue Code and related financial crimes in a manner that fosters confidence in the tax system and compliance with the law. It is surprisingly easy for a person to find oneself involved with this sort of IRS tax problem like Tax Evasion or Tax Fraud. Some of your clients might not be aware that anything had gone wrong until the IRS came looking for them. A criminal investigation differs from an audit. With an audit, the IRS attempts to determine whether you have calculated your tax liability correctly. With a criminal investigation, the IRS seeks to mount a case against you so that the U.S. Attorney’s Office can prosecute you. 

When clients find themselves the target of an IRS criminal investigation, most taxpayers suddenly realize they need an attorney. How does the accountant respond when the client calls and says “I have a problem?” However, one of the key players in defending the taxpayer will be the accountant who works in the background to help the defense recreate expenses, attack overzealous numbers from the IRS criminal investigation, and act as experts for the criminal defense.  This program will explain the key roles played by accountants, the role of tax loss calculations in the case, and why many accountants realize that criminal cases are not only fascinating to work on but can be extremely lucrative engagements. 

This session of this online CPE/CE webinar will cover:

  • How does the accountant disclose information to the IRS without violating the Client or Accountant's rights?
  • What are the client’s rights regarding records given to the Accountant?
  • Can the Accountant be an expert or fact witness for the Client? 
  • Will the Accountant be a witness for the Prosecution? 
  • How can the Accountant prevent being a target of the Investigation? 
  • Has the Accountant did all the required Due Diligence in the preparation of the Return?
  • Does the Accountant need a lawyer? Is the Government there to help you?
  • When the Accountant has prepared the return that is subsequently under Criminal Investigation by the Internal Revenue Service, 
  • What does the accountant need to do when return prepared by him is under Criminal Investigation? 
In this session, all these things will be discussed and answers will be provided that will help the Accountants to be prepared during a Criminal Investigation of the Client.


In 2006, Congress passed the Tax Relief and Health Care Act. Prior to the Act’s passage, rewards to individuals who provided information to the IRS regarding tax fraud were capped at $10 million. The Tax Relief and Health Care Act authorized the IRS to create a Whistleblower Office dedicated to investigating, processing, and recovering claims concerning the underpayment of taxes. Under the IRS’ new program, whistleblowers may recover 15 to 30 percent of the amount collected provided the taxes and amounts in dispute exceed $2 million.

The IRS whistleblower program allows anyone who is aware of tax underpayments to apply for a whistleblower award using IRS form 211. The IRS then reviews the whistleblower’s submission and determines what action should be taken. As a part of this process, whistleblowers may be interviewed for more information. Whistleblowers are entitled to compensation if their information leads directly to an IRS recovery of at least $2 million, including interest and penalties. After the completion of a successful investigation, the IRS Whistleblower Office provides the whistleblower with an award determination.

This session of this continuing education course will teach you how to add an extremely profitable revenue stream to your practice. Learn how to submit a Whistleblower Claim to the IRS on behalf of your Client/Whistleblower.

This session of this online CPE webinar will cover:

  • How to increase your chances of the Claim being accepted and Rewards paid. 
  • What the IRS is looking for in a claim and how they determine "Reward Amounts". 
  • How to appeal the Claim Reward?
  • How to find out exactly how much of your Whistleblower Information was used. 
  • How Does long a normal claim take from beginning to end?
  • How much has been paid by the Government on all Whistleblower Claims during the fiscal year 2019. 

Taxpayers have a legal duty to comply with U.S. Tax Laws. If you owe the IRS money, it is usually only a matter of time before they come to collect. Whether you failed to file, did not disclose all of your income, or for any other reason, getting in touch with them before they come after you is always the better scenario. To make it easier, the IRS and many states have a program called Voluntary Disclosure, wherein an individual or organization can come forward and volunteer information before the situation worsens.

The IRS Voluntary Disclosure Program gives taxpayers an opportunity to safely disclose their offshore accounts, assets, income, and investments to the Internal Revenue Service (IRS). "Voluntary Compliance" is the cornerstone of our tax system. lt is estimated over 85% of taxpayers comply with their Tax Obligations. While most taxpayer's voluntary comply, some fail to do so. IRS has a wide variety of civil and criminal sanctions that maybe imposed on non-compliant taxpayers. Failure to voluntarily comply may result in imprisonment, fines, and penalties.

This session of this online CE webinar will cover:

  • Learn how the Accountant can help their client who has not voluntarily complied with their tax obligations.
  • Submitting a voluntary disclosure to the Internal Revenue Service requires specialized knowledge and expertise.
A Voluntary Disclosure may be a means to resolve your client's non-compliance and limit exposure to criminal prosecution.

This session of this continuing education course will provide great insight into the Tax professionals that want to establish their selves in most paying practices.

Click to access more webinars on Latest Tax Updates | IRS Audit | Trust & Estate Planning

Learning Objectives

  • Recall the process for bringing non-filers back into the tax season
  • The process of income estimation if income related information cannot be produced by the client.
  • To identfy the various answer of the questions from Internal Revenue Criminal Investigators during the Interview of you and your knowledge of the client’s return preparation.
  • To identify the ways of interacting with your client, so you do not violate the Clients rights nor the Accountants.
  • To identify the the definition of TAX LOSS, which is the guideline for the length of Incarceration for Tax Crimes.

Who Should Attend?

  • Accountant
  • Accounting Firm
  • Accounting Managers
  • Accounting Practice Owners
  • Bookkeepers & Accountants & Tax Preparers
  • California Registered Tax Professional
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • Entrepreneurial CPA
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Senior Accountant
  • Staff of Accounting Firm
  • Tax Attorney
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Young CPA