One of the most significant issues identified by the IRS, Department of Justice Tax Division and Treasury Inspector General for Tax Administration (TIGTA) is unpaid payroll taxes. In the last 5 years the IRS has become much more aggressive in its plan to close this area of the annual tax gap, including increased enforcement. The impact of the IRS's increased enforcement activities is to send more taxpayers scrambling for professional help in resolving their payroll tax problems. In addition, IRS Criminal Tax enforcement and prosecutions in the payroll tax area is up almost 3,000%!
Unpaid payroll tax liabilities in particular have become a huge issue for small businesses. The key success factor in assisting businesses and business owners with their payroll tax issues is understanding the rules of how the IRS Collection Division works, how IRC Section 6672 functions, and knowing where the opportunities are to resolve the matter. This course will also review the recent IRS program of contacting employers who fail to deposit payroll taxes, as well as the upsurge in criminal tax prosecutions and what business owners need to be thinking about.
This online CPE seminar with highly regarded tax controversy expert, Eric L. Green, J.D., LL.M. of Green & Sklarz, LLC in Connecticut and New York, will provide a practical review of payroll tax issues, IRS assessment and collection procedures, including recent changes rolled out by the IRS in 2012, third-party liability issues under IRC Section 6672 and IRC Section 3505, and strategies for business owners to minimize or avoid personal liability.
• The "Tax Gap"
• Assessment and Collection procedures against the business
• The IRC Section 6672 Trust Fund Recovery Penalty
• Third-Party Liability under IRC Section 3505
• The procedure for IRS assessment of and collection against responsible individuals
• Strategies for minimizing personal liability
• Options for resolving outstanding payroll tax liabilities
Understand payroll taxes and the trust fund recovery penalty.
Identify steps to take and opportunities to help clients resolve their IRS payroll tax debt.
Understand what factors are considered by the IRS when deciding to forward a case for criminal tax prosecution.
Eric is a partner in Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York. The focus of Attorney Eric L. Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services, as well as handling probate matters and estate planning for individuals and business owners and tax planning for closely held businesses. He is a frequent lecturer on tax topics for CCH, the NAEA, the NATP, the ABA Tax Section and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He is the author The Accountant’s Guide to IRS Collection (available www.tgpublish.com), and he is a columnist for CCH’s Journal of Practice & Procedure. He is also the founder of The New England IRS Representation Conference. Mr. Green is a contributing author for Advocating for Low Income Taxpayers: A Clinical Studies Casebook, 3rd Edition, and has also been quoted in The Wall Street Journal, USA Today, Consumer Reports, The Wall Street Journal’s Market Watch, TheStreet.com and CreditCard.com. Prior to practicing law Attorney Green served as a senior tax consultant for KPMG and Deloitte & Touche. Attorney Green was the 2010 Nolan Fellow of the American Bar Association and has served as Chair of the American Bar Association’s Closely Held Businesses Tax Committee. Attorney Green is the current Chair of the Executive Committee of the Connecticut Bar Association’s Tax Section. Eric is a Fellow of the American College of Tax Counsel (“ACTC”). Attorney Green is also a member of the Connecticut, Massachusetts and New York Bar Associations, as well as the American Bar Association. Attorney Green is admitted to practice in Massachusetts, New York and Connecticut Superior Courts, the United States Tax Court, The Federal Court of Claims and the Federal District Court for Connecticut. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honors graduate from New England School of Law. He earned a Masters of Laws in Taxation (LL.M.) from Boston University School of Law.
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