The TCJA made sweeping changes to the Internal Revenue Code, and while Treasury and the IRS have done a Herculean job of providing guidance, many of the changes are complex and there is scant legislative history to reveal what Congress intended. Certain provisions of the TCJA will be caught in a cross-current of complexity and ambiguity that may lead some taxpayers to take aggressive reporting positions. This panel identifies some of those provisions and the areas in which controversies are likely to ensue.
Identify areas of confusion and controversy resulting from the Tax Cuts and Jobs Act (TCJA).
Tamera Ripperda (Tammy) is the Deputy Commissioner of the Small Business/Self Employed Division (SB/SE) business operating division where she provides executive leadership and direction for the design, development and delivery of a comprehensive tax administration program to meet the needs of over 57 million small business owners and self-employed taxpayers with business interests having less than $10 million of assets.
Tammy returned to SB/SE in March 2019 after a 14-month assignment as a director in the Tax Reform Implementation Office (the TRIO) where she served as one of the five executives charged with overseeing the implementation of the Tax Cuts and Jobs Act (TCJA) of 2017. This law represented the largest overhaul of the Internal Revenue Code since 1986 and involved all aspects of tax administration for individuals and businesses. The TCJA implementation involved hundreds of employees from IRS, Counsel, Treasury, and the Office of Management and Budget.
Claudia Hill is an Enrolled Agent, nationally recognized tax professional and frequent lecturer on taxation of individuals and representation before IRS. She is Editor in Chief of the WoltersKluwer, (formerly CCH) Journal of Tax Practice & Procedure, co-author of CCH Expert Treatise Tax Practice & Procedure, and a frequent presenter for both audio and inperson CPE seminars nationwide. Claudia coordinates a “dream team of tax controversy advisors” for the IRS Watch blog on Forbes.com (http://blogs.forbes.com/irswatch/). She was named a Top Ten Nominee by Tax Analysts as 2011 Person of the Year.
Claudia is owner and principal of Tax Mam, Inc. and TMI Tax Services Group, Inc. in Cupertino, CA. TMI Tax Services Group offers tax return preparation, tax planning, and tax problem resolution and representation services, primarily to individual clients. She is often called upon by the news media as a resource person for commentary on tax topics. Her articles and observations have appeared in CCH publications as well as Tax Analysts, Forbes.com and industry professional journals. Her mission to reform or eliminate the individual AMT has been the focus of a number of articles. In March 2005, Claudia was invited to testify about the individual AMT at the President’s Tax Reform Panel.
Michael Sardar has extensive experience on a wide range of tax controversy and white collar criminal defense matters. Mr. Sardar represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice and local prosecutors.
Fred Murray is an attorney (District of Columbia, Maryland, New York, and Texas (Board Certified in Tax Law, Texas Board of Legal Specialization), and various federal courts) and C.P.A. (Maryland and Texas).
His experience includes public law and accounting practice, government service as Deputy Assistant Attorney General in the Tax Division at the Department of Justice and as a Special Counsel to the Chief Counsel for the Internal Revenue Service, where he was involved in drafting of legislation and testimony, legislative investigations, and other Congressional matters, litigation, and in regulations, revenue rulings and other agency guidance. Fred also served as Vice President for Tax Policy at the National Foreign Trade Council and General Counsel and Director of Tax Affairs at the Tax Executives Institute. He testified on behalf of the private sector in the Senate Foreign Relations Committee on the Venezuela and Italy tax treaties, and in the House Ways & Means Committee on tax reform, and helped manage the passage of billions of dollars of international tax legislation.
Andrew (Andy) R. Roberson focuses his practice on tax controversy and litigation matters. He represents clients before the Internal Revenue Service (IRS) Examination Division and Appeals Office and has been involved in over 60 matters at all levels of the federal court system, including the US Tax Court, several US Courts of Appeal and the Supreme Court. Andy has experience settling tax disputes through alternative dispute resolution procedures, including Fast Track Settlement and Post-Appeals Mediation, and in representing clients in Compliance Assurance Process (CAP) audits. He also represents individuals in Global High Wealth Industry Group audits and in connection with offshore disclosure programs.
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