3710 Tax Shelter Law Enforcement: Perils for Practitioners
Price: $ 119.00 (USD)
Add to Cart
You will receive 1.25 credits (CE) upon completion of this course.
Have a question about this course? .
Course Description
The Internal Revenue Service and the U.S. Department of Justice are taking a more aggressive, criminally-oriented stance toward attorneys and others who recommend potentially illegal tax shelters. A panel that includes the Chief of Criminal Investigation at the IRS, the Principal Deputy Assistant Attorney General of the Tax Division at the U.S. Department of Justice, and two distinguished private practice tax ligitators discuss the policy, Circular 230, the new likelihood of parallel criminal and civil cases, the impact of the policy on attorney-client privilege and on attorney opinions, and whether the policy imposes policing obligations on attorneys.
Back to Top
Course Outline
Tax Shelter Law Enforcement: Perils for Practitioners
I. Introduction
A. Panelists
B. Background
C. Historical View
II. Current Enforcement Focus
A. IRS Focus on Enforcement
B. IRS Focus on Practitioners
C. Circular 230
D. Too Much Focus on Circular 230?
E. § 6700 Examinations and § 7408 Proceedings
F. IRS Guiding Principles for Enforcement
G. Expansion Enforcement?
III. Privilege
A. Summons Enforcement Law
B. Attorney-Client Privilege
C. Statutory Backdrop for Attorney-Client Privilege
D. Worth Getting a Legal Opinion?
IV. Criminal Prosecutions
A. Obligations on Practitioners
B. Disqualified Practitioner Opinions
C. Criminal or Civil Case?
D. Criminal Indictments of Tax Professionals?
AfterWordsSM
Back to Top
I. Introduction
A. Panelists
B. Background
C. Historical View
II. Current Enforcement Focus
A. IRS Focus on Enforcement
B. IRS Focus on Practitioners
C. Circular 230
D. Too Much Focus on Circular 230?
E. § 6700 Examinations and § 7408 Proceedings
F. IRS Guiding Principles for Enforcement
G. Expansion Enforcement?
III. Privilege
A. Summons Enforcement Law
B. Attorney-Client Privilege
C. Statutory Backdrop for Attorney-Client Privilege
D. Worth Getting a Legal Opinion?
IV. Criminal Prosecutions
A. Obligations on Practitioners
B. Disqualified Practitioner Opinions
C. Criminal or Civil Case?
D. Criminal Indictments of Tax Professionals?
AfterWordsSM
More Information
| Language | English |
| Course Length | 1.25 hours |
| Duration of Access | for 3 months from day of enrollment |
| Continuing Education Credits | 1.25 |
| Instructor | James A. Bruton, Miriam L. Fisher, Nancy J. Jardini, Christopher S. Rizek, Rod J. Rosenstein |
| Vendor | Cognistar (Read more about Cognistar accreditation.) |
| Course Certification | CLE credit available, see details for each course for states where available |
| Prerequisites/Audience | intended for attorneys and law students |
| Requirements/Materials Included | computer with Internet access |
Price: $ 119.00 (USD)
Add to Cart