EVENT DESCRIPTION
Strategies for Nonfilers provides a comprehensive deep dive into the legal, procedural, and tactical complexities of bringing noncompliant taxpayers back into the system. This session moves beyond basic filing requirements to examine the nuances of voluntary disclosure, the criteria for "reasonable cause" versus "willful neglect," and the mechanics of Substitute for Returns (SFRs) generated by the IRS. We will analyze how to prioritize multiple years of unfiled returns, navigate the nuances of the IRS Fresh Start program for back taxes, and manage the delicate balance of criminal versus civil exposure. Whether dealing with a simple oversight or years of systemic non-compliance, this course equips practitioners with the advocacy tools needed to mitigate penalties and secure the best possible resolution for their clients.
EVENT OBJECTIVE
• Evaluate the legal and financial risks associated with various classes of nonfilers, including individuals, small businesses, and those with offshore reporting requirements.
• Analyze the IRS Voluntary Disclosure Practice (VDP) and determine when a formal disclosure is necessary versus a "quiet disclosure" or standard late filing.
• Identify the procedural triggers for an IRS Substitute for Return (SFR) and outline strategies to challenge or replace these assessments with actual returns.
• Apply "Reasonable Cause" standards to successfully advocate for the abatement of failure-to-file and failure-to-pay penalties.
• Develop structured resolution plans for nonfilers, including the use of Installment Agreements, Offers in Compromise, and "Currently Not Collectible" status once compliance is achieved.
• Differentiate between civil non-compliance and criminal tax evasion indicators to properly manage practitioner-client privilege and referral risks.
