IRS Nonfiler Representation – Representing Taxpayers That Have Not Filed Tax Returns

This webinar will focus on representing taxpayers that have not filed tax returns. We will discuss unfiled returns by individuals and entities. This program will discuss how to address unfiled income tax returns, employment tax returns, Foreign Bank Account Reports, and other domestic and foreign information returns. We will discuss best practice when representing taxpayer with unfiled returns, including how many years or periods to file, what disclosures to include, whether there are voluntary disclosure programs available, and how to minimize or abate penalties.

Webinar Objectives

This webinar will provide insight and tools to assist you and your clients understand the various ways to address unfiled returns. You will learn how to prepare and file a reasonable cause statement with the unfiled returns to try and avoid penalties. You will also learn how to try and abate penalties due to the taxpayer’s unfiled and late returns. We will also discuss how to address unfiled returns during audits, collections, and criminal investigations.

Webinar Highlights

• The available processes to file unfiled returns
• Contesting penalties assessed or proposed related to the unfiled returns
• How to put forth a reasonable cause defense to penalties
• Civil versus criminal risk with unfiled returns
• How to address unfiled domestic and foreign information returns

Who Should Attend

Accountants, tax preparers, CFOs, financial compliance professionals, and lawyers

Client Testimonial (MarcT)

This was my second tax law related seminar (one on civil tax fraud and the other on penalty abatement requests) presented by attorney Adam Fayne. He explains the complex clearly (e.g., the elements of civil tax fraud, defenses, and the IRS’s burden of proof), he understands what he is talking about (e.g., frequently providing numerous real-world examples from his own tax law practice), and he has depth of knowledge of tax law (which is rare for such a vast topic). He does the little things that a seminar attendee would appreciate. His slides seen throughout the seminar are a helpful and concise resource for later reference. Also, Mr. Fayne  took the time at the beginning to let us know about a recent US Tax Court decision decided days before the seminar that provides potential refund opportunities to taxpayers inappropriately assessed “Form 5471 penalties.” Similarly, he mentioned and cited on slides, when relevant, citations to the tax code, the  Internal Revenue Manual, and case law. I’d give both seminars I have attended my highest recommendation to experienced tax practitioners, as well as those new to that practice.