This panel included a report from the Tax Court, discussion of significant IRS guidance and litigation, an update on Tax Division priorities, a report from Treasury, and a discussion of significant pending litigation. 

Recent instances of exposure by the press of aggressive tax planning and tax avoidance by prominent businesses, individuals or families raise unique substantive, ethical, and other legal issues for the tax community. Practitioners advising famous clients may need to assess not only the likelihood of future examinations, but also public disclosure due to whistleblowers, cooperators, and data leaks.

Reducing burdens in the tax filing process is a key goal for policymakers. As the filing season is upon us, this panel explored key ways that the IRS and Congress have attempted to make the process simpler for taxpayers, including the introduction of a postcard Form 1040, an increase in the standard deduction and the creation of an Annual Filing Season Program designed to give taxpayers greater information about the qualifications of unlicensed tax return preparers.

The panel included Richard E. Zuckerman | Deputy Assistant Attorney General for Criminal Matters and Principal Deputy Assistant Attorney General, U.S. Department of Justice Tax Division.

Taxpayers can become aware they are the subject of a criminal tax investigation with notice of a summons, a grand jury subpoena or execution of a search warrant and end in a declination of prosecution, a plea or a trial. 

This list appeared in the December 2017 issue. The latest list will launch January 1, 2019.

Washington has a higher concentration of people with JDs than anywhere else in the country, which means you’re probably out of luck if you want to pick a fight with the homeowners’ association over landscaping rules—chances are the HOA president litigates much higher-stakes matters for a living. Also, you should really keep your voice down if you must tell that lawyer joke while riding Metro. Finally, it means this list is pretty tough to compile.

The penalty rules for tax return preparers pose significant challenges for tax practitioners and their clients. There often is a great amount of uncertainty about what a “tax shelter” is and when and how to disclose return positions. Practitioners must also wrestle with regard to conducting proper due diligence, understanding the standards of conduct necessary to avoid 6694 penalties and determining when to rely on information provided by clients or third parties.

Practitioners are often faced with ethical conundrums in everyday practice.  The representation of spouses in an exam, discovering information not reported in a prior year, issues with financial information that surfaces after it has been provided to the IRS, etc.  Our panel of practitioner and government experts reviewed these situations and discussed them so that attendees will know what to do (and not do) when these issues arise.

New voluntary disclosure guidelines apply to both foreign and domestic disclosures and include a penalty framework and access to Appeals.

Obtain clarity in changing times.

The monumental passing of the Tax Cuts and Jobs Act results in historic tax reform impacting nearly every American. This has brought about exciting opportunities for CPAs and financial planners. Your guidance will help your affluent clients achieve their financial goals and help you generate new business.