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Amounts withheld from employee wages account for 70% of all revenues collected by the U.S Department of the Treasury, and as of September 2015, more than $59 billion of tax reported as due on employment tax returns remained unpaid. The IRS and the Tax Division of the Department of Justice recently identified civil and criminal employment tax enforcement as among the agencies’ top priorities.
This webinar, jointly offered by two leading tax controversy attorneys, will discuss:
(1) employer’s federal employment tax filing and withholding obligations;
(2) the trust fund recovery penalty under section 6672 of the Internal Revenue Code, who is a responsible person, and when a responsible person acts “willfully” to support the imposition of the trust fund recovery penalty;
(3) how continued noncompliance with employment tax obligations can result in criminal investigation and prosecution;
(4) the assessment and collection of the trust fund recovery penalty;
(5) rights before IRS collection and IRS Appeals to challenge a trust fund recovery penalty pre-assessment;
(6) strategies to challenge and prevent the assessment of the trust fund recovery penalty;
(7) how to resolve multiple trust fund recovery penalty assessments against more than one responsible person(s); and
(8) an introduction to trust fund recovery penalty litigation.
This webinar is a must-attend for practitioners who service companies that have payroll taxes.
Kimberly, TX
"I truly enjoyed learning the "nuts and bolts" of the "after the fact" unpaid payroll taxes. As a CPA in private industry, who worked as a F/C Bookkeeper and Cost/Managerial Accountant for many years before I became a CPA, this was a fine reminder of why it was always paramount to me to ensure that my employer's taxes were paid and reported in a timely fashion, but you shared LAW and procedure that reiterates why it is always most important to know every facet of a subject. Thank you for the procedural information, and recent TAX Court updates for further study and review."
Atiq, CA
"It was great program about employment taxes and maintenance of Trust accounting. The assessment of penalties in case of improper account maintenance handling, showing the method to take care of and also understanding IRS rules and regulations. The consequences and it's remedy. Very helpful guidelines and advises.I highly recommend to attend these kind of webiners. Thanks. Crescent Tax Services Pomona, CA 91767"
Angela, AZ
"I am well versed in TFRP issues, as I was a Revenue Officer for 27 years and an Appeals Officer for 13 years. I still found some very useful information in the presentation, particularly the strategies in dealing with the Service as well as possible criminal implications. Thanks for a great presentation."
Pamela, IL
"Great presentation - I learned a lot. Being able to go in & review the written text ("screens") from the webinar after the fact is very helpful. CPA Academy's 60 to 90 minute classes are a great way to take a "learning break" in the middle of my work day and keep current with Tax and IRS issues."
James, MI
"Highest level of competence by presenters on subject matter. Generously shared handout information that helps practitioners to properly relate to complex area of Tax Law. Very helpful in adding to skill and understanding of specialized area of Revenue Code"
Michael, MO
"Not only are Larry & Jairo's webinars informative, they are super well organized & offer tips for practitioners to navigate the increasingly complex minefield of changing tax laws & regulations. They are superstars & their offerings are highly recommended."
Madeline, FL
"The presenters for this webinar are knowledgeable and engaging on this important but often misunderstood topic. The webinar Powerpoint materials also provide a good outline of what the tax professional needs to know to represent a client on TFRP issues."
Alice, GA
"The webinar provided me with information about Assessment procedures and Report of Interview the were unknown to me. The assessment Procedure and Strategy were particularly helpful for consultation with clients."
Lawrence A. Sannicandro, Esq., LL.M., J.D., MBA
McCarter & English, LLP
Attorney
lsannicandro@mccarter.com
9736392081
Lawrence (“Larry”) Sannicandro is an associate in the Tax, Employee Benefits & Private Clients Practice Group who concentrates his practice on tax controversy and tax planning matters. He represents businesses, estates, trusts, and individuals at all stages of tax controversies, including in audits, before the IRS Office of Appeals, and in litigation before the United States Tax Court, the U.S. Court of Federal Claims, the U.S. District Courts, and the U.S. Courts of Appeals.
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