Webinar: Getting Ready for Audits: A Practitioner’s Guide to Navigating IRS Scrutiny by ALFI

IRS enforcement on Employee Retention Credit claims intensifies, so practitioners need to be ready and equipped with practical tools to navigate the agency's scrutiny with confidence. This webinar covers the primary ERC audit issues and the latest guidance from IR-2024-169 and Kwong v. United States.

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Presenter

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

About

Program Field of Study: Taxes/Federal Tax Related Matters
Program Level: Basic
Credits: 1 CPE | 1 CE | 1 CLE
Advanced Preparation: None
Prerequisite: None

Join Frost Law Partners Rebecca Sheppard and Peter Haukebo to review COVID-19 Relief Programs and audit basics in order to discuss the top issues ripe for IRS audit, like controlled groups, family attribution rules, qualified wages, and PPP+ offsets. They will cover ERC eligibility methods, substantiation, case theory development, and the latest updates on IR-2024-69 and Kwong v. United States to ensure you as a practitioner are audit ready.

This webinar is approved for MCLE credit in Virginia. Check the reciprocity and riles for your state's bar association to see if they grant out-of-state credits. Credit hours subject to each state's approval and attorneys may self-apply for CLE credit.

Agenda

Identify the top issues most likely to trigger IRS audit scrutiny in Employee Retention Credit claims, including supply chain arguments, ownership aggregation, family attribution rules, and qualified wage calculations.
Summarize the three methods of ERC eligibility — significant decline in gross receipts, full/partial suspension of business operations, and Recovery Startup Business status — and the documentation required to substantiate each.
Evaluate whether a business may be part of a controlled group under brother-sister rules and assess how family attribution rules could affect ERC eligibility and qualified wage determinations.
Discuss the implications of Kwong v. United States and IRS IR-2024-169 on current ERC audit activity, including the scope of automatic deadline extensions and the IRS's ongoing compliance enforcement efforts.
Demonstrate the ability to research and apply appropriate governmental orders to support a partial suspension claim, distinguishing between qualifying mandatory orders and non-qualifying government statements or emergency declarations.