About Jim Malone, Peter Hardy, Carolyn Kendall

Post & Schell’s Tax Controversy Practice Group has extensive knowledge of the law, coupled with broad experience in civil and criminal litigation and in conducting administrative proceedings. We represent corporate and individual taxpayers, as well as tax preparers and accountants, involved in tax controversies with the IRS and with state and local tax authorities. Click here to learn more >>

Enforcement Priorities: Employment Taxes and International Tax Issues

shutterstock_304875527We recently had the pleasure of speaking with Marie Sapirie of Tax Analysts on two areas of tax enforcement: employment taxes and international compliance programs. Marie’s story ran in the February 1, 2016 edition of Tax Notes; you can access it here.

 … Read More

Registration is Open for the 2016 Employment Tax Forum in Philadelphia on Feb. 25th

Employment Tax Forum RSVP BANNER - 2016

We are happy to announce that registration is now open for the 2016 Employment Tax Forum, taking place February 25, 2016 at 8:15 am in our Philadelphia Office.

Employment Tax Forum ButtonThe IRS has made clear that employment tax enforcement is a current priority. The Employment Tax Forum provides tax professionals – including accountants, return preparers, auditors and attorneys – with an overview of federal employment tax issues, including worker classification, and an update on related federal civil and criminal enforcement initiatives.The event begins with breakfast, followed by two panel sessions with current and former IRS officials, as well as experienced practitioners.

Free CPE and CLE will also be offered.Read More

Employment Tax Forum to Take Place February 25th in Philadelphia

Employment Banner - Tax

Throughout 2015, the IRS made clear that employment tax enforcement is a current priority. This is something we’ve discussed in past posts, as well heard first hand from IRS agents and officials at conferences and other venues.

Against this backdrop, we’re pleased to announce that we’ll hold The Employment Tax Forum on February 25, 2016 here in our Philadelphia Office. The goal is to provide tax professionals – including accountants, return preparers, auditors and attorneys – with an overview of federal employment tax issues, including worker classification, and an update on related federal civil and criminal enforcement initiatives. Free CPE and CLE will also be offered.… Read More

DOJ Tax Division and IRS Officials Describe Civil Tax Enforcement Priorities

CE1512CTF Print Brochure_1Speaking at the ABA’s Annual Criminal Tax Fraud and Tax Controversy Conference, senior officials from the Tax Division of the Department of Justice (DOJ) and the IRS Office of Chief Counsel described a variety of priorities for civil enforcement.

Consistent with prior indications that payroll taxes will be a significant area of focused criminal enforcement, Diana L. Erbsen, Deputy Assistant Attorney General for Appellate and Review, indicated that practitioners should anticipate civil actions for injunctive relief in payroll tax cases, followed by contempt proceedings to enforce those injunctions. Erbsen also indicated that the Financial Litigation Unit of the Office of Review, which focuses on collecting tax judgments, has received additional staff and is expected to be more active.… Read More

IRS Executives Discuss the Service’s Current Initiatives: Focus on Employment Tax Compliance and Digital Communications

IRS Rep ConferenceSpeaking on a panel this morning at the New England IRS Representation Conference, several Washington IRS executives discussed the Service’s current initiatives. We heard from Mary Beth Murphy, Deputy Commissioner, Small Business/Self-Employed Division; Rajive Mathur, Director of Online Services; Carole Madison, Acting Director of Examination, North Atlantic Region; and Darren Guillot, IRS Director of Field Collections. Below are some of the highlights from their discussion.

Employment Tax Compliance
As we have discussed before, one of the IRS’s stated enforcement priorities is employment tax compliance. According to Mr. Guillot, employer withholding of income and payroll taxes accounts for approximately 70 percent of the nation’s tax revenue.… Read More

Employers Beware: AAG Ciraolo Emphasizes Employment Taxes as Enforcement Priority

Department of Justice

U.S. Department of Justice places employment taxes high on its list of enforcement priorities

We had the pleasure today of hearing the comments of Caroline Ciraolo, Acting Assistant Attorney General (AAG) for the Tax Division of the U.S. Department of Justice (DOJ), regarding DOJ Tax Division’s current enforcement priorities. Acting AAG Ciraolo provided one of the keynote addresses at the American Law Institute’s Continuing Legal Education conference, Handling a Tax Controversy: Current Trends in Civil Tax Controversies and Litigation, held in Washington, D.C. This blog entry will focus on, just as Acting AAG Ciraolo did, the issue of employment tax enforcement.… Read More