Amounts withheld from employee wages account for 70% of all revenues collected by the U.S Department of the Treasury, and as of September 2015, more than $59 billion of tax reported as due on employment tax returns remained unpaid. The IRS and the Tax Division of the Department of Justice recently identified civil and criminal employment tax enforcement as among the agencies’ top priorities.
This webinar, jointly offered by two leading tax controversy attorneys, will discuss:
(1) employer’s federal employment tax filing and withholding obligations;
(2) the trust fund recovery penalty under section 6672 of the Internal Revenue Code, who is a responsible person, and when a responsible person acts “willfully” to support the imposition of the trust fund recovery penalty;
(3) how continued noncompliance with employment tax obligations can result in criminal investigation and prosecution;
(4) the assessment and collection of the trust fund recovery penalty;
(5) rights before IRS collection and IRS Appeals to challenge a trust fund recovery penalty pre-assessment;
(6) strategies to challenge and prevent the assessment of the trust fund recovery penalty;
(7) how to resolve multiple trust fund recovery penalty assessments against more than one responsible person(s); and
(8) an introduction to trust fund recovery penalty litigation.
This webinar is a must-attend for practitioners who service companies that have payroll taxes.
"Excellent information coupled with real life examples and recommended best practices!"
"Great webinar. There was so much good information it could have easily gone twice as long!"
"The presenters for this webinar are knowledgeable and engaging on this important but often misunderstood topic. The webinar Powerpoint materials also provide a good outline of what the tax professional needs to know to represent a client on TFRP issues."
"This webinar was put together very well. Very informative and relevant."
"Wonderful, Wonderful, wonderful."
"As a former, now retired revenue officer and revenue officer advisor, I thought this course was fantastic and exceeded my expectations."
Lawrence A. Sannicandro is a tax controversy and litigation attorney with Agostino & Associates, P.C., where he counsels businesses and individuals at all stages of tax controversies. He regularly represents clients in audits, before the IRS Office of Appeals, and in litigation before the United States Courts of Appeals, the United States Tax Court, the United States Court of Federal Claims, the United States District Courts. Prior to entering private practice, Mr. Sannicandro served as a law clerk for the United States Tax Court, and before that, as an attorney for the IRS. He earned his LL.M. in Taxation from Georgetown University Law Center, J.D. from the University of Florida Levin College of Law, and M.B.A. in Finance from Binghamton University. He is a frequent author on tax practice and procedure, and is a contributing author to David Laro, Shannon P. Pratt & Michael R. Devitt, Qualified Appraiser, Qualified Appraisal: Practice, Procedure, Legal Analysis, and Theory.
Jairo G. Cano is an associate with Agostino & Associates, P.C. He regularly represents clients in complex Federal and State tax controversy matters before the Internal Revenue Service, the New Jersey Division of Taxation and New York Department of Taxation and Finance. Jairo routinely appears on behalf of clients in audits, Appeals hearings, collection proceedings and litigation before the United States Tax Court, New Jersey Tax Court and United States District Courts.
Prior to joining Agostino & Associates, Jairo worked for the New Jersey Office of the Attorney General in the Treasury Section where he handled gross income tax, corporation business tax, sales & use tax and various other tax cases.
Jairo currently serves as Vice-Chair of the ABA Tax Section’s Diversity Committee. In 2015, Jairo was selected as a Nolan Fellow by the American Bar Association’s Tax Section. Each year, this award is given to a select group of outstanding young tax lawyers from across the country who make significant contributions to the organization and who demonstrate leadership qualities.
Jairo graduated from Seton Hall University School of Law and obtained an LL.M. degree in Taxation from the University of Florida Levin College of Law.
CPAwebengage, Inc. (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.
CPAwebengage Inc. 1857. W 34th Ave, Denver, CO 80211
CPAwebengage, Inc. (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary. <br/><br/> <strong>CPAwebengage Inc. 1857. W 34th Ave, Denver, CO 80211</strong>