On October 26, 2021, Caroline D. Ciraolo presents “When Avoidance Crosses the Line: Criminal Investigation of Abusive Tax Schemes” for the 56th Annual Southern Federal Tax Institute.
Description: The IRS has ramped up its efforts to combat abusive tax schemes. Enhanced coordination and collaboration is providing IRS personnel with the tools and training to identify promoters, investors, and professional enablers, and to pursue civil examinations, promoter investigations and, where warranted, criminal investigations. Individuals and entities caught in this web are battling on multiple fronts and frequently dealing with government agencies pursuing different objectives and seeking divergent resolutions. This presentation will review the current enforcement landscape with respect to syndicated conservation easements and micro-captive insurance companies, the need to avoid conflicts, best practices for protecting privileges, responding to multiple requests for documents and information, managing public perception, defending criminal allegations, and more.
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