Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2027 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
The federal government has become increasingly aggressive in seizing and forfeiting assets, financial accounts, and even entire businesses in both the civil and criminal contexts. This course provides practical insights and important updates to enable CPAs and Enrolled Agents to help their clients avoid asset forfeitures, defend against them, and navigate through receiverships and seizures of business and personal assets.
Publication Date: June 2024
Topics Covered
- Introduction to Forfeitures
- IRS Initiatives Suggest More Forfeitures
- IRS/DOJ Forfeiture Policies and Procedures
- Forfeiture Crimes/SUAs
- Avoiding Forfeiture Risks in Audits
- Avoiding Accountant/Enrolled Agent Liability Risks
Learning Objectives
- Recognize financial misconduct that may lead to asset forfeitures
- Recognize circumstances raising risks of asset forfeitures
- Identify how to avoid tax reporting pitfalls when addressing potentially illegally sourced funds
- Recognize IRS Civil and Criminal Initiatives focusing on foreign financial assets, cryptocurrency, cannabis businesses, and tech crimes
- Identify strategies to navigate and efficiently comply with government receiverships and seizures
Level
Overview
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructor
Randall P. Andreozzi
Mr. Andreozzi’s legal career has focused on resolution of complex tax controversy matters, large case (corporate) tax matters, tax shelter litigation, employee welfare benefit litigation, and international/territorial tax issues.
For 16 years, Mr. Andreozzi worked for the IRS Office of Chief Counsel, where he served as Industry Counsel for the Commissioner’s Industry Specialization Program (ISP). He evaluated and litigated tax cases presenting Welfare Benefit Plan issues. Mr. Andreozzi litigated many seminal cases in this area, including General Signal Corp. v. Commissioner, Booth v. Commissioner, Parker Hannifin Corporation v. Commissioner, Square D Co. v. Commissioner and Neonatology Associates v. Commissioner. He also assisted and counseled other IRS attorneys and revenue agents in their development of cases under the ISP program, offering valuable expertise in areas involving tax shelters and the corporate income tax consequences of VEBAs and Welfare Benefit Plans.
During his years with the IRS Chief Counsel’s office, Mr. Andreozzi cultivated a strong reputation with attorneys and agents throughout IRS, as well as with outside tax practitioners nationwide. His extensive trial experience extends to other complex tax areas as well. Mr. Andreozzi tried a variety of complex precedential cases that have established important precedent in the areas of abusive tax shelters, corporate acquisitions (INDOPCO v. Commissioner), international taxation, United States Virgin Islands territorial taxation, and TEFRA partnerships.
Now in private practice with the firm of Lippes Mathias LLP, Mr. Andreozzi continues to focus his practice on complex tax litigation and tax controversy resolution. His practice areas include international taxation and foreign bank account reporting, criminal tax and financial crime defense, employee benefit taxation, tax shelter litigation, and a variety of emerging areas of federal and state tax law.
Mr. Andreozzi has published numerous articles on taxation, and frequently lectures on a variety of current and developing tax issues. He is an Adjunct Professor at the State University of New York (SUNY) at Buffalo School of Management, where he teaches Business Law at both the graduate and undergraduate levels. While he was with the IRS Office of Chief Counsel, he trained Chief Counsel trial attorneys at national litigation schools.