Christopher Rizek and Melissa Wiley Analyze Captive Insurance and Conservation Easements at AICPA National Tax Conference

In recent years the IRS has focused considerable resources on enforcement activities in two areas: captive insurance and conservation easements. These campaigns present challenges not just to the IRS, but to taxpayers and taxpayer advisors and representatives. The presenters on this panel have been in the thick of these actions, on both sides. They will discuss the IRS’s activities and settlement initiatives, strategies for dealing with them, and lessons that can be applied to future similar enforcement efforts by the IRS. Discussion topics will include:

• IRS campaign initiatives, staffing, and coordination
• IRS focus on abusive schemes and penalties, including the civil fraud penalty
• Settlement initiatives
• Appeals and litigation

Learning Objectives:

• Describe how IRS identifies certain transactions or planning for further scrutiny and possible identification as a tax shelter
• Identify current status of two recent high profile tax shelter targets: microcaptive insurance companies and conservation easements