TOPICS (SUBJECT TO CHANGE)

IRS CRIMINAL INVESTIGATIONS INTERVIEW - Tony Box will discuss Criminal Investigations.  The presentation will include a role player exercise of an interview in a criminal tax case.  Presented by Tony Box and Brandon Lewis. 

LLCs AS S CORPS:  Advantages, Challenges and Busts - A survey of the business and tax issues encountered when LLCs elect S Corp status.  Presented by Dan Baucum.

Taxpayer Advocate - We are proud to have Erin Collins, the National Taxpayer Advocate, address our conference.  Ms. Collins will discuss some of the problems her office is seeing in the past year of so.  She will also address her recommendations to Congress.  

CYBERSECURTY:  IRS's will review the tax professional's responsibility.  Presented by LaTanya Bacon, IRS

NEW COMPREHENSIVE IRS VOLUNTARY DISCLOSURE PROGRAM:  KEY ASPECTS AND ITS EVOLUTION - International tax enforcement has garnered significant attention, but taxpayers still have domestic problems, too.  Fortunately, the IRS announced a comprehensive program in 2018.  It then issued four sets of additional guidance in the following years, most recently in 2022.  Some issues remain ambiguous, but the new program offers a path for taxpayers to resolve foreign and/or domestic programs for all varieties.  This presentation identifies the U.S. tax and information-reporting duties, explains multiple disclosure programs currently offered by the IRS and analyzes the scope, pros, cons, and other critical aspects of the new comprehensive program.   Presented by Hale Sheppard. 

UPDATE ON THE NEW RESEARCH AND DEVELOPMENT CAPITALIZATION RULES - The Tax Cut and Jobs Act included a provision that R & D expenses would need to be capitalized beginning in 2022.  Taxpayers have been able to take  R & D expenses since 1954.  With these new rules now enacted we will help you identify the clients impacted and expenses within those clients that will need to be identified.   Presented by Randy Crabtree. 

UNDERSTANDING LLC AND PARTNERSHIP BASIS - Different rules apply to the allocation of basis among LLC members and partners depending upon whether the debt is recourse, nonrecourse or partner nonrecourse.  Special rules can apply in limited partnerships that may not be intuitive.  Since basis affects deductibility and taxability of deductioins, precision is key.  Presented by Clint Davis.

DEALING WITH ERRONEOUS REFUNDS - Errors happen.   And sometimes they favor your clients or seem to when your client receives refunds from the IRS that are too large.  This presentation will explain the difference between rebate and non-rebate erroneous refunds.  That difference has important consequences for how the IRS can recover the erroneous refund from your client and, thus, what advice you should be giving your client. 

UNITED STATES TAX COURT PRACTICE AND PROCEDURE - Kyle Coleman will discuss the jurisdiction of the United States Tax Court and the basics of filing a Tax Court Petition.  He will also discuss practice and procedures before the Tax Court for both professionals and pro se clients.

ACS Updates - We all work with ACS whether we do a lot of representation or not.  In some ways ACS is more difficult to work with than a revenue officer because every time you call, you end up speaking to a different person.  Tiffany Morice who oversees four call sites and two paper Operations and a Support Operation will give us the latest on ACS. 

IRS OFFICE OF FRAUD ENFORCEMENT - Thomas Kramer, IRS 

UNDERSTANDING THE ASSESSMENT STATUTE EXPIRATION DATE (ASED) - Generally the IRS has three years from the date a return is filed to examine the return and assists any taxes over and above what was reported on the return.  This presentation will help you understand what triggers the three-year clock and what extends it.   Presented by Bryan Camp.

SUCCESSION PLANNING FOR FAMILY BUSINESSES:  STATE, FEDERAL AND ESTATE/GIFT TAX CONSIDERATIONS - This panel will discuss a myriad of practical tax and estate planning issues associated with transferring a family business to the next generation.   Presented by Christi Mondrik and Rob Hugos.

IMPLEMENTATION AND GOVERNMENT ENFORCEMENT OF BLOCKCHAIN TECHNOLOGY AND DIGITAL ASSETS:  Speakers will provide an update on the latest legislation, regulation, and court cases involving digital assets as well as practical examples of how these new assets are impacting traditional industries.  Presented by Joshua Smeltzer and Brian Clark. 

IRS APPEALS - WRITING A WINNING/EFFECTIVE PROTEST - In response to an IRS Examination RAR, containing disputed audit adjustments, this session will discuss the mechanics of drafting a successful protest to achieve desired results.  Presented by David Stubblefield. 

OFFICE OF PROFESSIONAL RESPONSIBILITY - OPR will review the latest developments affecting the tax professional community.  (2 hours ethics for EAs)  Presented by Timothy McCormally.