Criminal Tax Issues
Includes a Live Event on 09/29/2020 at 11:00 AM (EDT)
In the daily circumstances of a tax practice, a practitioner will learn facts that may require the client to amend a return or to file a delinquent form. It can be a challenge for a tax practitioner to know the difference between a routine correction and a potential criminal matter. It is therefore helpful to understand what facts and circumstances might be relevant to IRS for consideration as a criminal matter. Learn why it is important to be able to evaluate your clients’ facts and circumstances for potential badges of fraud, what those badges of fraud are and what IRS must show to establish a criminal case. We will cover the difference between a willful violation of law and simple negligence, criminal tax statutes and relevant case law, when it is necessary to bring in an attorney, and assisting an attorney under a Kovel arrangement.
IRS CE: 1 Hours/Federal Tax Law Update
NASBA CE: 1 Hours/Federal Tax Law Update
CTEC CE: 1 Hours/Federal Tax Law Update
NSA ConnectED Webinar CPE Bonanza
Program Level: Basic
Advance Preparation: None
Delivery Method: Group-Internet Based
No refunds or exchanges for cancellations. For more information regarding refund, complaint and/or program cancellation policies, please contact NSA toll-free at 800-966-6679.
NSA is approced by NASBA, the IRS, ACAT, and CTEC as a provider of continuing professional education.
Kevin Murphy served for many years as an attorney with the U.S.Treasury Department, Office of Chief Counsel and also concurrently as a SpecialAssistant United States Attorney, representing the IRS in Tax Court andBankruptcy Court. Kevin was an instructor for Chief Counsel courses andrecently worked on a successful initiative that created and implemented a processto collect and review metadata and electronic documents. He was alsoassigned to an offshore compliance team dealing with foreign bank and financialreporting requirements under the Bank Secrecy Act. He developed and analyzedissues in the area of offshore compliance and the Offshore Voluntary DisclosureProgram.
Kevin is an adjunct professor of law with the Wehle School ofBusiness at Canisius College and has taught in the MBA and in the Masters inTax program at Canisius. He is licensed to practice in New York andPennsylvania and is admitted to the US Tax Court and US District Court WDNY.His graduated from The American University, cum laude and he earned his lawdegree at Catholic University.
Kevinserved in the military with the U.S. Coast Guard Reserve and is a formerofficer with the U.S. Secret Service.
Mr. Andreozzi’s legal career has focused on resolution of complex tax controversy matters, large case (corporate) tax matters, tax shelter litigation, employee welfare benefit litigation, and international/territorial tax issues.
For 16 years, Mr. Andreozzi worked for the IRS Office of Chief Counsel, where he served as Industry Counsel for the Commissioner’s Industry Specialization Program (ISP). He evaluated and litigated tax cases presenting Welfare Benefit Plan issues. Mr. Andreozzi litigated many seminal cases in this area, including General Signal Corp. v. Commissioner, Booth v. Commissioner, Parker Hannifin Corporation v. Commissioner, Square D Co. v. Commissioner and Neonatology Associates v. Commissioner. He also assisted and counseled other IRS attorneys and revenue agents in their development of cases under the ISP program, offering valuable expertise in areas involving tax shelters and the corporate income tax consequences of VEBAs and Welfare Benefit Plans.
During his years with the IRS Chief Counsel’s office, Mr. Andreozzi cultivated a strong reputation with attorneys and agents throughout IRS, as well as with outside tax practitioners nationwide. His extensive trial experience extends to other complex tax areas as well. Mr. Andreozzi tried a variety of complex precedential cases that have established important precedent in the areas of abusive tax shelters, corporate acquisitions (INDOPCO v. Commissioner), international taxation, United States Virgin Islands territorial taxation, and TEFRA partnerships.
Now in private practice with the firm of Andreozzi Bluestein LLP, Mr. Andreozzi continues to focus his practice on complex tax litigation and tax controversy resolution. His practice areas include international taxation and foreign bank account reporting, criminal tax and financial crime defense, employee benefit taxation, tax shelter litigation, and a variety emerging areas of federal and state tax law.
Mr. Andreozzi has published numerous articles on taxation, and frequently lectures on a variety of current and developing tax issues. He is an Adjunct Professor at the State University of New York (SUNY) at Buffalo School of Management, where he teaches Business Law at both the graduate and undergraduate levels. While he was with the IRS Office of Chief Counsel, he trained Chief Counsel trial attorneys at national litigation schools.