2025 IRS Criminal Investigations and Civil Tax Fraud

When it comes to tax fraud, the stakes are high, and the lines between civil and criminal can quickly blur. In this session, tax attorney Adam Fayne will walk you through what tax fraud can look like—whether it’s underreporting income, excessive business deductions, hiding assets (both domestic and international), structuring, misclassifying employees, or failing to file accurate 941s and handling Trust Fund issues.

Adam will break down the serious consequences of civil fraud penalties, which can reach up to 75% of the understated tax. More importantly, you’ll learn practical strategies for representing clients during audits where fraud is suspected. The goal? Keeping the case civil and avoiding a DOJ referral for criminal indictment.

Throughout the session, Adam will share tools and techniques to help you negotiate penalties and minimize risk for your clients. If you’re navigating the tricky waters of tax fraud, this program will give you the insights you need to achieve the best possible outcomes.

Webinar Objectives

• Identify key tax fraud triggers, such as underreporting income, hiding assets, or employee misclassification.
• Understand the critical differences between civil and criminal tax fraud cases.
• Review IRS processes for determining whether a case remains civil or escalates to criminal.
• Learn practical strategies to protect clients during fraud audits and prevent DOJ referrals.
• Develop tools to negotiate reduced penalties and achieve the best possible outcomes for your clients.

Webinar Highlights

• The difference between civil fraud and criminal charges.
• The process the IRS uses to determine whether to keep a case civil or criminal.
• The various methods to try and negotiate that the case remain civil, and not criminal.
• The applicable penalties in civil tax fraud cases.
• How to negotiate the reduction of the civil tax fraud penalty.

Who Should Attend

Accountants, Tax Preparers, CFOs, Financial Compliance Professionals, and Lawyers

Credit(s)

IRS CPE Credits: 1 Tax hour