Statistically, nearly 80% of small businesses fail, often owing payroll taxes. The IRS resolves many of these situations with its civil enforcement tools, but some are referred to IRS Criminal Investigation. So, what makes one case a civil matter and another case ripe for criminal investigation and prosecution? Our panel of experts will review the statutory framework, applicable rules, and regulations, and steps employers can take if they find themselves falling behind on their employment tax obligations to avoid a criminal referral.
The IRS Representation Conference brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The Conference covers a wide range of representation issues, from procedural seminars to substantive programs, estate & gift issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.
This comprehensive, two full-day event focuses on the practical issues and how to handle them rather than theoretical issues.
View further details on the event here.
Please note: Enrolling in an individual session will grant you access to the entire two-day event.
Green & Sklarz LLC
Partner
egreen@gs-lawfirm.com
(203) 285-8545
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. His practice also handles 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 of 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. Before 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”) and a Connecticut, Massachusetts, New York, and American Bar Association member. He is admitted to practice in Massachusetts, New York, and Connecticut Superior Courts, as well as 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 honor graduate from New England School of Law. He earned a Masters of Laws in Taxation (LL.M.) from Boston University School of Law.
Kostelanetz LLP
Partner
cciraolo@kflaw.com
(443) 845-4898
Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and tax tribunals, providing related tax advice, including advice on uncertain tax positions, financial reporting, claims for refund, amended returns, voluntary disclosures, and internal investigations, and representing individuals and institutions in criminal tax investigations and prosecutions.
IRS
Executive Director, Fraud Enforcement Office, Small Business and Self-Employed Division
As the Director of the Office of Fraud Enforcement, Damon Rowe provides IRS service-wide leadership and guidance related to the development and delivery of significant activities in support of IRS’ efforts to detect and deter fraud. This encompasses focusing on taxpayers and professional enablers’ unethical actions that undermine our Federal Tax Laws and address emerging threats related to fraudulent filings and related activities. In this position, he also acts as the principal advisor and consultant to IRS Division Commissioners and Deputy Commissioners on all issues involving fraud enforcement strategic plans, programs, and policy.
Mr. Rowe began his IRS career in 1998 in Criminal Investigation (CI) as a Special Agent in Los Angeles, CA. Since then, he has held positions with increasing responsibility, including serving as a Senior Analyst in the Narcotics and Counterterrorism section and a Supervisory Special Agent in the Dallas Field Office (2007 – 2011). In late 2011, Mr. Rowe was promoted to Assistant Special Agent in Charge for the New Orleans Field Office. In January 2014, he was promoted to Special Agent in Charge of the Dallas Field Office and subsequently returned to Los Angeles as the Special Agent in Charge in April 2017.
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