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.
McCarter & English, LLP
Attorney
lsannicandro@mccarter.com
9736392081
Lawrence (“Larry”) Sannicandro is an associate in the Tax, Employee Benefits & Private Clients Practice Group who concentrates his practice on tax controversy and tax planning matters. He represents businesses, estates, trusts, and individuals at all stages of tax controversies, including in audits, before the IRS Office of Appeals, and in litigation before the United States Tax Court, the U.S. Court of Federal Claims, the U.S. District Courts, and the U.S. Courts of Appeals.
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