Upcoming Live Stream Premiere
April 20, 2022
8:00 am HST, 11:00 am PT, 2:00 pm ET
"Current Developments and Trends in IRS Audit and Investigations (And How to Avoid Becoming a Target)"
Speakers: Caroline Ciraolo, Michael Desmond, Nathan Hochman & Steven Toscher
Having spent the last two years creating and building the Office of Fraud Enforcement, appointing and staffing National Fraud Counsel, and instituting and expanding the Office of Promoter Investigations, and with billions of dollars in funding on the horizon, the IRS is poised to launch an unprecedented era of enforcement. With new personnel, enhanced training, heightened internal cooperation among operating divisions, expanded information reporting for “digital assets” and ongoing collaboration with federal agencies and treaty partners, we anticipate increased fraud referrals, new compliance campaigns, and more parallel proceedings targeting taxpayers participating in abusive tax avoidance schemes and their professional enablers. Meanwhile, standards for judicial review of regulations and other guidance continue to evolve, opening new paths for taxpayers to challenge IRS enforcement actions. This panel will discuss what to expect in 2022 including, but not limited to, a continued focus on high income non-filers, high wealth taxpayers engaged in abusive transactions, cryptocurrency reporting and enforcement, foreign reporting obligations, residency incentive programs, Maltese pension plans, inflated business credits, and monetized installment sales.
CE Credits: 1.5 Hours
Caroline Ciraolo, Attorney
Caroline is a former acting assistant attorney general of the U.S. Department of Justice’s Tax Division, and is now a partner with Kostelanetz & Fink, founder of the D.C. Office. Her practice focuses on civil tax controversies, including sensitive audits, administrative appeals and litigation, related tax advice, internal investigations and criminal tax investigations and prosecutions.
Michael Desmond, Attorney
Michael Desmond is a partner in the Washington D.C. and Los Angeles offices of Gibson Dunn & Crutcher and a member of the Firm’s Tax Practice Group. Prior to joining Gibson Dunn, Mike served as the 48th Chief Counsel of the IRS, where he was the principal legal officer, overseeing a staff of nearly 1,500 lawyers responsible for interpreting and providing advice on all aspects of the federal tax law and for litigation of more than 25,000 cases pending in the United States Tax Court.
Nathan Hochman, Attorney
Nathan Hochman is a former Assistant Attorney General of the U.S. Department of Justice’s Tax Division, a former federal prosecutor and one of the nation’s leading lawyers in tax and criminal litigation. He has been the chair or deputy chair of two major international law firms’ White Collar defense practices and a former President of the Los Angeles City Ethics Commission. Nathan is currently a partner at Ellis George Cipollone O’Brien and Annaguey.
Steven Toscher, Attorney
Steven Toscher is a tax attorney and principal of the law firm Hochman, Salkin, Toscher & Perez where he specializes in civil and criminal tax litigation. Prior to entering private practice, Mr. Toscher served as a trial attorney with the Tax Division of the United States Department of Justice, where he received its outstanding attorney award.