Virtual Event: Trust Fund Recovery Penalities & Criminal Tax
IRS Program #: X9QQU-T-01098-23-O
CE: 1 IRS credit for Criminal Tax & 2 IRS credits for Trust Fund Recovery
Materials
Criminal Tax
In this session we will be focusing on the badges of fraud that IRS Civil and Criminal Investigation evaluate to determine if a fraud referral should be made or criminal tax charges brought. Additionally, we will describe the role of a Kovel accountant and when to refer a client to a tax attorney for legal advice.
Learning Objectives
- What are IRS CI’s Priorities in FY 2023?
- Describe when a civil tax case potentially rises to a criminal tax investigation.
- Understand the role of a non-attorney practitioner in a criminal tax investigation.
- Identify when to refer a client to an attorney.
Trust Fund Recovery Penalties
In this session we will define Trust Fund as it relates to business owners with employees and who is considered a responsible office if Trust Fund taxes are not paid. The failure to pay Trust Funds taxes may result in the IRS Collection Division to refer the responsible officers to the IRS Criminal Investigation Division for criminal prosecution if badges of fraud are present.
Learning Objectives
- Define Trust Fund Taxes (IRC 6672).
- Who is a Responsible Person?
- What are the Willfulness Factors?
- Preparing a Reasonable Cause Statement.
Presenters
David Gannaway, EA, MBA, CFE, CAMS, CVA
Mr. Gannaway joined J.S.Heldin November 2020 as an executive vice president in the Forensic Accounting & Economics Group. Since 2007, he has been providing tax controversy, litigation support, and expert witness services to attorneys and clients in both civil and criminal litigations in federal and state courts across multiple business sectors including construction, healthcare, financial services, and nonprofit.
Read their full bio here!
Mr. Gannaway joined J.S.Heldin November 2020 as an executive vice president in the Forensic Accounting & Economics Group. Since 2007, he has been providing tax controversy, litigation support, and expert witness services to attorneys and clients in both civil and criminal litigations in federal and state courts across multiple business sectors including construction, healthcare, financial services, and nonprofit.
Read their full bio here!
Continuing Education
This course qualifies for IRS Continuing Education Hours. NAEA reports IRS CE on a monthly basis. If you have not received your CE Hours in your IRS PTIN Account by the end of the month after receiving the certificate, please contact NAEA at
education@naea.org. IRS Requirements for live webinars require at least 50 minutes per hour of attendance and answering 3 out of the 4 polling questions. For on-demand, you must watch the full video, answer the knowledge check, and pass the assessment with a score of 70% or above. No partial CE is offered.
Webinar Refund Policy
To request a refund, contact the NAEA education team via email at
education@naea.org. An NAEA education team member will review the request for a refund. If the refund request has been approved, the refund will be refunded on the same method of purchase. Live Webinars, also offered On-Demand will not be refunded.