Designed as a comprehensive technical manual for the 2026 tax enforcement landscape, this course equips practitioners with the forensic tools necessary to navigate the IRS's aggressive eradication of marketed tax shelters.
DESIGNED FOR
CPAs and accounting professionals in public practice and industry who advise individuals and closely held businesses on tax matters
BENEFITS
- Understand how courts and the IRS are prioritizing substantive valuation analysis over technical compliance and are rejecting aggressive land valuation models.
- Identify emerging multi-entity and trust-based structures that violate dominion, control or capital-gain recognition principles.
- Evaluate ethical and liability risks when relying on black-box technology or white-labeled diligence and marketing materials.
- Recognize the limits of opinion-based reasonable cause defenses and the narrow, time-sensitive nature of remediation options such as Qualified Amended Returns.
HIGHLIGHTS
Items to be covered in this webinar include:
- Judicial and IRS attacks on valuation theories, including rejection of HBU "Unicorn" assumptions and DCF models in conservation easement cases
- Emerging tax shelter structures and enforcement targets, including Charitable LLCs and abusive CRATs
- Professional responsibility risks involving technology reliance, white-labeled diligence, and promoter-provided materials
- Penalty defense and post-transaction remediation, including reasonable cause, QARs, and John Doe summonses