Penalty Proofing Your Client's 199A Deduction: How To Avoid Penalties
This class will prove to be one of Bob’s most timely, insightful and actionable classes. Joining Bob will be Michael Goller, JD a nationally recognized tax lawyer who has taught practice and procedure at the graduate school level and for 1,000s of CPAs and tax lawyers. Michael brings an unmatched understanding of the law along with a practical approach to protecting your clients.
The Section 199A statute, regulations, and guidance leave many common questions unanswered. Therefore, many practitioners must evaluate what position to take and whether there is sufficient authority. Part of this analysis is determining what, if any, penalties might apply should the IRS prevail on audit. Some of the more difficult issues are:
-   Framing out the critical Section 199A issues with penalty exposure
-   Reviewing the trade or business issue and the multi-entity issue
-   Addressing aggregation elections and penalties and Notice 2019-7 Elections
-   Understanding the separate and separable issue
-   Understanding the statutory employee issue
-   Understanding the multiple trust rules and the impact of these provisions
-   Understanding the various penalties under the Internal Revenue Code
-   Understanding the levels of assurance for penalty waivers
-   Understanding how and when to use opinion letters to reduce a client’s exposure
-   Finally, how and when to use form 8275 disclosures
Practitioners also need to be acutely aware of the impact on the Sec. 6662(b)(2) substantial-understatement penalty. For taxpayers that take a Sec. 199A deduction, a special rule decreases the threshold that triggers the penalty from an understatement that is 10% of the tax required to be shown on the original return or $5,000, to an understatement that is 5% of the tax required to be shown on the original return or $5,000 (Sec. 6662(d)(1)(C)).
With a basic understanding of how to disclose positions and demonstrate sufficient authority for the position, the accuracy-related penalty can be avoided. This highly practical and actionable webinar will teach you how to penalty-proof your clients' 199A positions.
There will be no CE for this webinar
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Michael G. Goller is a shareholder and chair of Reinhart’s Tax Practice. He is a member of the firm’s Litigation and Corporate Law Practices. His practice focuses on tax controversy, tax litigation, and tax planning. The clients Michael represents include large, public corporations, mid-sized, privately held businesses and their owners. He handles a wide variety of tax-related issues, including complex income and estate and gift tax controversies. Michael represents clients involved in disputes with the IRS, the Department of Justice, and various other taxing authorities before the United States Tax Court, various Federal district courts, the United States Court of Federal Claims, various state courts and the Seventh Circuit Court of Appeals.
As an experienced tax attorney and tax litigator, Michael assists his clients in navigating the challenges associated with complex federal and state tax audits, disputes, administrative appeals, trials and subsequent appeals. Michael serves as a trusted advisor and legal strategist who is able to draw upon his vast knowledge and experience to offers unparalleled proficiency in his field, which is evidenced in his impressive track record of successfully trying cases to favorable settlements. Clients appreciate that Michael has the personality of litigator with the expertise of a tax attorney and provides legal advice from this unique intersection.