CPAacademy.org | FROM BAD TO WORSE: WHEN AN AUDIT GOES CRIMINAL

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FROM BAD TO WORSE: WHEN AN AUDIT GOES CRIMINAL - PART I

Cost Free

CPE Credits 1.0 hour

Subject Area 1.0 - Taxes (Federal Tax Update)

CE Credits 1.0 hour

Course Id# - HURS9-U-00110-16-O

Course Level Basic

Instructional Method Group Internet Based

Prerequisites None

Advanced Preparation None

Who Should Attend CFO / Controller
CPA - small firm
CPA - medium firm
CPA - large firm
Enrolled Agent
Other

Series: CFOs and Controllers, Enrolled Agents, Taxes

Course Description

This presentation will provide accountants and other tax professionals with an understanding of the stages of a criminal tax case and the strategies available at each stage to avoid a criminal trial. In Part I, panelists will discuss the sources of criminal tax cases and the evaluation and investigation involved in an “eggshell audit”. The panelists will also cover the coordination between the IRS civil team and IRS criminal investigation division.

Learning Objectives

gain an understanding of the criminal tax process and procedural complexity as compared to a civil audit
learn how to identify potential criminal tax issues early
develop an understanding of the IRS’ varying investigative techniques to identify criminal tax issues
learn how to distinguish potential civil penalty issues from criminal issues
gain insight regarding how to defend a “sensitive” audit with criminal issues or a parallel proceeding
learn to identify various points in the criminal tax process where resolution is most likely

Joshua Wu

Latham & Watkins LLP
Counsel
joshua.wu@lw.com
(202) 637-3376

Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.

Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.

Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm.

Additional Materials

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Frequently Asked Questions

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Handout Materials

Presentation Slides

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About Our Presenter

Clark Hill is a multidisciplinary international law firm that draws on its attorneys’ comprehensive industry and policy knowledge, deeply held shared values, and a global network of premier firms and advisors to provide effective legal solutions and client-service excellence. One of the top 100 firms in the United States — with over 600 attorneys and professionals in 25 offices across the nation, as well as offices in Dublin and Mexico City, we are a committed partner to a diverse range of leading brands, forward-thinking businesses, public entities, nonprofit organizations and individuals. Our significant presence in Washington, DC, and our deep government relations and public affairs experience at every level help ensure that our clients’ voices are heard in the development of federal and state regulatory policy and legislation.