Our Blog

This week’s episode of the TRN Podcast is a quick one, but that doesn’t mean it’s any less important. In fact, we felt it was necessary to give a fast update because this topic is so significant right now.

The IRS recently posted a new announcement to its website stating that the IRS Enforcement and Compliance Operations are officially now back to normal. What does this mean? It means that the IRS has flipped the switch on automated levies and on automated notices of federal taxing.

The switch was officially flipped on June 15^th. As a result, roughly millions upon millions upon millions (yes, it’s that rough) of final notices and LT11s, will go out to taxpayers. Additionally, notices of federal tax liens will go out, because, since April 2020, the IRS has held off on this tactic due to COVID-19.

Simply put, it seems as if the IRS is viewing the world as “back to normal.” As such, it’s time to start enforcing normal responsibilities again. That being said, with LT11s and final notices of intent-to-levies going out, what do you need to know? What should you be doing right now?

Tune in to this week’s podcast episode. These questions—and plenty more—will be answered in detail to help ensure you’re taking the right measures for yourself and your business.

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

We have John Nail and Laura Gavioli joining Eric for this week’s episode of the TRN Podcast, and the discussion revolves around voluntary disclosure.

John is a tax controversy attorney with Chamberlain Hrdlicka in Atlanta, Georgia. He focuses on civilly and criminally representing taxpayers before the IRS and exams appeal litigation in federal district court and US tax court.

Laura is also a tax controversy attorney, but with Alston Bird in New York. She represents those taxpayers facing civil and criminal tax issues.

Additionally, John, Laura, and Eric Green are committee buddies from the ABA tax section, the civil and criminal penalties’ committee, where they are all part of the subcommittee on voluntary disclosures.

Naturally, John and Laura are perfect for this conversation.

Once introductions are made to the audience, Eric begins the chat by mentioning that the IRS has had a domestic voluntary disclosure program for quite some time. Then, John describes what voluntary disclosure really is and how it works.

Specifically, today, voluntary disclosure is geared towards all types of tax—both foreign and domestic. John states, “The concept of the voluntary disclosure is the taxpayer coming forward in a timely manner, providing truthful and complete information—a lot of information—to the government.”

And if you want to hear the rest, you’ll have to listen to the full podcast—available now!

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

Joining this week’s episode of the Tax Rep Network Podcast is Megan Brackney. Megan is a partner at Kostelanetz & Fink in New York, where she does civil and criminal tax controversy work.

Before joining the Kostelanetz & Fink team, Megan was an Assistant United States Attorney in the Southern District of New York. Additionally, she was an Assistant Attorney General for the State of Missouri. Today, she is consistently recognized as one of New York’s super lawyers. She has given speeches all over the United States and written extensively on tax controversies, matrimonial divorce issues, immigration, and tax issues.

Megan is with us now to discuss Form 8300. The 8300 is the form that reports the receipt of cash payments of over $10,000 received in trade or business. It can be administered under the Bank Secrecy Act, but also under the Internal Revenue Code.

In Megan’s words, “Essentially, the form is a way for the IRS and treasury to track cash transactions that occur in the United States. And so, as the form indicates, if you receive more than $10,000 in a transaction or related transactions in a trade or business, the business is required to file this form and take some other steps related to compliance under these statutes.”

And that’s only the beginning of our chat! There’s plenty more in store.

If you are interested in learning about Form 8300, including specific details and explanations from Megan, then you don’t want to miss the full podcast. Available now!

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

Joining the Tax Rep Network Podcast this week is Alex Robnett, the Chief Strategy Officer at Elementus, a blockchain data firm headquartered in New York. With previous roles involved in front office work, risk management, and operations for several insurers, Alex now focuses his efforts on communicating Elementus’ superior ability to index blockchain information while handling business operations for a growing company.

Alex is here to continue the chat we’ve been having for a few weeks now that centers around IRS enforcement. Specifically, there is a correlation between IRS enforcement and blockchain technology, which is just one topic Alex is going to discuss in detail.

To give you a little bit of background on Alex: He holds a BS in Business Administration from the University of Tennessee and a Masters of Finance from Fairfield University.

Towards the beginning of the conversation, Alex notes that there are numerous buzzwords floating around his industry right now. He begins by referring to a ledger, in the realm of cryptocurrency, and the idea that cryptocurrency runs on decentralized technology, the notion of a decentralized ledger is considered blockchain technology.

What does this mean, exactly? You’ll have to listen to the full conversation to find out. Additionally, if you’re an accountant or related to the industry in some manner, then you’ll have no problem following along. You’ll even find the episode informative and very interesting.

The episode is available now; don’t miss it!

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

On this week’s episode of the TRN Podcast, we’re talking more about whistleblower cases. Specifically, this conversation gives the IRS’s perspective. Joining us again is Mike Villa, as well as Supervisory Special Agent Gary Alford. Gary was previously on the podcast to discuss Silk Road. We felt it was important for the audience to gain a deeper, firsthand understanding of what happens when these cases are brought to the attention of an IRS professional, and what occurs afterward.

To start, for those who didn’t tune in for the first segment on whistleblower cases, Mike offers a bit of a recap. He mentions how the whistleblower program works, particularly what happens when a third party brings to the attention of the government unfiled forms, misfiled forms, and/or unpaid taxes. Of course, the person who brings this information forward is eligible for a whistleblower reward. However, before that can take place, the entire process begins with Form 211. Once Form 211 is filled out properly and filed, it is up to the IRS to either make a case or not. Please note: This is all information that was highlighted in the first podcast episode dedicated to whistleblower cases.

Moving forward, Mike and Gary share their specific encounters with whistleblower cases, giving an interesting insight into their personal experiences. We guarantee you won’t want to miss this chat! Even if you missed the previous whistleblower episode, this second edition is still enjoyable and easy to follow. Or, better yet, go back and listen to the first episode before playing this one. Available now!

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

This week’s episode, Episode 100, marks a milestone for Tax Rep Network Podcast. Joining podcast host Eric Green is Amy Vetter, an accomplished entrepreneur, business executive, national speaker, CPA, yoga practitioner, and technologist. She is a third-generation woman entrepreneur who has launched and sold multiple businesses including owning and operating her own yoga studios, accounting practice, and other business ventures.

Before Amy began her entrepreneurial journey, she was Partner at a CPA firm—which is “the ultimate goal” for many in the industry. But Amy decided that it wasn’t the right path for her. So, what happens when you decide your current career isn’t what you want to be doing?

The truth is: there are many unhappy people out there who are stuck in a career they hate, but are hesitant to change the status quo. What they don’t realize is that this change doesn’t need to be the radical shift it sounds like–it’s completely doable!

In this episode, the topic of discussion is “How to Do What You Love.” Eric and Amy will discuss how those who are struggling with their job and career can make a change and begin doing what they love. Listen in as both Eric and Amy dish about how they made their major career changes and have never looked back.  Find out what you can do today to start doing what you love in TRN’s centennial podcast episode.

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

The latest episode of the Tax Rep Network Podcast is hosted by Guinevere Moore. Guinevere is a tax controversy and tax litigation attorney in Chicago, Illinois. She represents taxpayers who have significant civil disputes or criminal disputes with the IRS.

Today, Guinevere is chatting about what tax professionals need to know in order to respond to Information Document Requests (IDRs), as well as requests for taxpayer interviews. These are critical components of representing taxpayers before the IRS. Additionally, it’s vital to understand what the IRS is looking for, what—as a professional—your ethical obligations are, and the best practices to follow to ensure client’s rights are preserved in all ways possible.

Guinevere begins the conversation by detailing what it means to represent a client in front of the IRS and all of the different interests at play, such as the fact that every client wants to be in a position to resolve their case at the IRS exam level. Oftentimes, taxpayers want to be able to resolve things at the exam level, but realistically, not everything can be. This must be kept in mind.

Further, it’s important for representatives who assist clients in responding to IRS requests for information and/or interviews to lay the proper foundation and groundwork to set the client up for success in the event that the case does go to the IRS appeals or litigation in tax court or in district court.

From there, things only get deeper and more interesting. We guarantee you won’t want to miss this episode of the Tax Rep Network Podcast. Available now!

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/

On this week’s episode of the Tax Rep Network podcast, we’re chatting about IRS enforcement and John Doe summonses. We’re thrilled to have Don Fort and Larry Sannicandro, both from Kostelanetz & Fink, joining us.

As most of you already know, Don is the Director of Investigations in Kostelanetz & Fink, as well as the immediate past Chief of the Internal Revenue Services Criminal Investigation Division. Having spent nearly 30 years in law enforcement for the Federal Government, Mr. Fort has deep expertise in financial crimes and has developed an extensive network of connections—both within and outside the government.

Larry is a frequent speaker all over the country, as well as at the New England Rep Conference. He is a partner at Kostelanetz & Fink and focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the U.S. Tax Court, federal district court, and the appellate courts.

Additionally, Larry has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, and everything about foreign assets and income.

This is a very timely topic that you won’t want to miss, discussed with leading industry professionals. Get instant access now!

Sign up for more episodes here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/