Fundamentals of Tax Noncompliance and Controversy
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About
This Course
In this program, attorneys will learn how to proceed once they realize their client has or may have tax compliance issues. Taxpayer compliance issues include taxpayers who have not been contacted by the Internal Revenue Service (IRS) but who may be at risk due to noncompliance and taxpayers who have had adjustments made against them or who have been penalized by the IRS. The course covers the process surrounding tax litigation.
Attorneys of all levels are encouraged to attend this course to explore strategies for aiding clients with tax compliance issues.
Learning Objectives:
- Explain how to communicate with taxpayers who are not in tax compliance
- Identify how to get noncompliant taxpayers back into compliance
- Detail what to expect during an examination
- Describe what to expect once the IRS has made an income tax adjustment
- Learn what to expect when the IRS has assessed penalties against the taxpayer
- Delineate how to proceed with tax litigation
Production Date: 2/15/2024
About the Presenters
Phil Colasanto, Esq.
Withers Bergman LLP
Practice Area: Taxation (+ 1 other areas)
Phillip's practice is focused on domestic and international tax controversy and compliance matters. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts. He has represented clients from audit through trial and at the appellate level.His experience includes examinations, collection matters, Appeals hearings (including collection due process hearings), innocent spouse relief, whistleblower claims, advising clients on international and domestic filing requirements, advising clients on compliance options, and oral argument before the Tax Court and Court of Appeals.Phillip received the New York County Lawyers' Association Pro Bono Award in 2022. He ...
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Michael Steffany, Esq.
Withers Bergman LLP
Practice Area: Taxation
Michael's practice focuses on domestic and international tax planning, compliance, and controversy resolution for individuals and closely held businesses. His experience includes examinations, collection matters, appeals hearings (including collection due process hearings), advising clients on international and domestic filing requirements, advising clients on compliance options, and US international inbound and outbound tax planning for both individual and entity taxpayers.Michael has spoken on various tax topics and at various forums, including the International Fiscal Association and most recently on Current Issues Shaping Tax Controversy before the Knowledge Group. He has also published several tax-related articles and been quoted by various publications ...
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Thomas Perkins, Esq.
Withers Bergman LLP
Practice Area: Taxation (+ 2 other areas)
Thomas focuses his practice on domestic and international tax planning, compliance, and controversy resolution for individuals and closely held businesses. Thomas is experienced in the areas of domestic and international taxation, international tax planning and compliance for businesses and individuals, contracts, and corporate law. He specializes in advising clients on the U.S. tax consequences of cross-border transactions, domestic and international withholding tax, FATCA and CRS reporting, legal and tax aspects of operating a business outside the U.S., structuring corporate transactions, tax treaty analysis, and compliance issues relating to U.S. tax and information reporting. Prior to joining Withers, Thomas worked at ...
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