Criminal Tax
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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 eggshell audits, criminal tax statutes, employment tax crimes, IRS enforcement programs and initiatives, relevant case law. We will also discuss when it is necessary to bring in an attorney, and assisting an attorney under a Kovel arrangement.
Learning Objectives:
After completing this course, an attendee will be able to:
- Eggshell Audits- identify a potential criminal case
- Classify facts and circumstances IRS considers for criminal cases
- Identify Red Flags
- Evaluate your client’s facts and circumstances
- Identify badges of fraud
- Recognize what IRS must prove to establish a criminal case
- Differentiate criminal tax statutes
- Identify when an attorney is needed
- Review employment Tax Crimes
- Identify privilege Issues and Kovel arrangements
- Describe IRS Enforcement Programs and Initiatives
CPE Credit: 1 hours Federal Tax Law
Speaker: Kevin Murphy
NSA Webinar Program Level: Basic Prerequisites: None 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 approved by NASBA, the IRS, ACAT, and CTEC as a provider of continuing professional education.
Kevin Murphy
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.
