Most practitioners and taxpayers are unaware that the employers may be held personally liable for their companies failure to pay employment taxes. This session will discuss how and when the IRS may hold company owners and officers personally liable for these employment taxes and what tools and strategies taxpayers can use to dispute and resolve these personal assessments. This webinar will provide an overview of the Trust Fund Recovery Penalty and also will discuss what happens when clients fail to pay Employment Taxes and file Forms 941.
Webinar Objectives
This webinar will help you identify those company individuals that the IRS may determine are “responsible officers” for purposes of being personally liable for the company’s employment tax obligations. We will discuss the process the IRS uses to determine who is a responsible officer and what rights taxpayers have to dispute the IRS’s claim. We will learn how to approach the IRS interview, what materials to provide, and how to appeal an adverse determination by the IRS.
Webinar Highlights
- What gives the IRS authority to hold company individuals personally liable for employment taxes.
- What is a “Responsible Officer”
- What tools are available to taxpayers to argue they should not held to be a responsible officer.
- Conflicts between company individuals and how to navigate those conflicts.
- Appeal rights when the IRS makes and adverse determination.
- How to deal with collections and enforcement actions.
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.
