IRS Crackdown on Abusive Trust Arrangements: Taxation, Audit Triggers, Reporting, DNI, Foreign Trusts
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide guidance to trusts and estates attorneys and tax professionals on IRS enforcement actions and examinations focused on abusive trust arrangements. The panel will discuss key areas of focus by the IRS in examining trust arrangements and related transactions, taxation of trusts and audit triggers, reporting issues and potential civil and criminal penalties, distributable net income (DNI), foreign trust challenges, and other items that are prime targets for an IRS examination of certain trust arrangements.
Outline
- Applicable tax rules and trust structures
- IRS enforcement initiatives
- Trust filing requirements
- Domestic trusts
- Foreign trusts
- Best practices for estate planners and taxpayers
Benefits
The panel will discuss these and other key issues:
- What are the applicable tax rules and reporting obligations for domestic and foreign trusts?
- What are the areas of focus of the IRS regarding abusive trust arrangements and transactions?
- How can estate planners and taxpayers avoid potential audit triggers in trust structuring and transactions?
- What are the key provisions or modifications available for trust documents in light of the IRS crackdown on trust arrangements?
Faculty
Cliff A. Capdevielle
Shareholder
Saltzman Mugan Dushoff
Mr. Capdevielle Capdevielle is a highly experienced probate, trust, and tax attorney with more than 30 years of... | Read More
Mr. Capdevielle Capdevielle is a highly experienced probate, trust, and tax attorney with more than 30 years of success representing trustees, beneficiaries, fiduciaries, and high-net-worth individuals in complex tax, estate, and trust, matters. Licensed in Nevada, California, and Texas, Cliff brings a unique cross-jurisdictional perspective to high-stakes disputes and sensitive family matters involving wealth transfer, inheritance, and fiduciary obligations. Before joining Saltzman Mugan Dushoff LLP, he served as Managing Attorney at Moskowitz LLP, a nationally recognized tax law firm, where he oversaw high dollar tax controversy matters. Earlier in his career, Mr. Capdevielle worked in the Tax Department at Deloitte, gaining deep experience at the intersection of tax law, finance, and business planning—expertise that now powers his sophisticated approach to estate, trust, and tax matters.
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Matthew L. Roberts
Partner
Meadows, Collier, Reed, Cousins, Crouch & Ungerman
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar... | Read More
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, Income Tax and Business Planning, and Cryptocurrency and Digital Assets. He is Board Certified in Tax Law by the Texas Board of Legal Specialization. Mr. Roberts is a tax litigator and trusted advisor with extensive experience assisting both U.S. and international clients in successfully resolving various federal tax controversies, including civil and criminal liability cases. His expertise covers a broad spectrum of issues, such as tax audits, investigations, litigation, appeals, and collection matters.
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