As the IRS continues modernizing its enforcement infrastructure, taxpayers and tax professionals are facing an increasingly data-driven audit environment. Advanced machine-learning systems, expanded digital asset monitoring, and evolving enforcement priorities under the One Big Beautiful Bill (OBBB) are significantly changing how the IRS identifies, evaluates, and escalates compliance risks.
This webinar will provide a practical understanding of the critical distinctions between civil IRS examinations and criminal tax investigations conducted by the IRS Criminal Investigation Division (IRS-CI). Participants will learn how civil audits can evolve into criminal matters, what indicators trigger fraud referrals, and how recent legislative and enforcement developments are impacting IRS examination strategies in 2026.
The session will also examine current IRS enforcement trends involving underreported income, payroll tax noncompliance, offshore reporting issues, cryptocurrency activity, and questionable deduction strategies associated with emerging OBBB provisions.
Attendees will gain practical guidance on interacting with Revenue Agents, Revenue Officers, and IRS Special Agents while understanding taxpayer rights, Fifth Amendment considerations, documentation risks, and representation strategies during high-risk IRS examinations and investigations.
Through real-world examples, procedural analysis, and compliance-focused instruction, participants will strengthen their ability to identify enforcement exposure, manage audit risks, and protect clients during sensitive IRS interactions.
Overview of the 2026 IRS enforcement environment and data-driven audit systems
Understanding how machine-learning technology is transforming IRS examinations
Differences between civil IRS audits and criminal IRS investigations
Civil versus criminal burdens of proof:
Understanding the IRS Criminal Investigation Division (IRS-CI)
Roles and responsibilities of:
How civil examinations are referred to criminal investigation units
Identifying the “Badges of Fraud” used in IRS fraud development cases
2026 fraud indicators and enforcement priorities under OBBB
IRS scrutiny of:
The impact of Qualified Production Property (QPP) deductions under OBBB
Managing cryptocurrency documentation and digital asset compliance risks
IRS data analytics and advanced enforcement technology considerations
Investigation procedures and audit timelines
IRS information requests, summonses, interviews, and evidence gathering
Understanding taxpayer rights and representation during IRS examinations
Fifth Amendment considerations during IRS investigations
Managing communications with IRS Special Agents
The IRS “Miranda Warning” and procedural considerations
Civil penalties, fraud penalties, and criminal tax exposure
Voluntary disclosure considerations and compliance strategies
Best practices for tax professionals handling high-risk IRS matters
Risk assessment, early intervention, and escalation management
Determining when legal counsel involvement is appropriate
Protecting clients and reducing enforcement exposure during IRS disputes
CPAs and Enrolled Agents (EAs)
Tax Attorneys and Legal Professionals
Compliance Officers and Risk Management Professionals
Financial Advisors and Wealth Management Professionals
Business Owners and Corporate Executives
Payroll and Tax Compliance Professionals
Professionals involved in IRS examinations and dispute resolution
Controllers and Finance Managers
Tax Resolution and Controversy Professionals
Anyone seeking practical guidance on IRS enforcement procedures and audit risk management
IRS / CPE Credits: 2.0 TAX
Delivery Method: Group Internet-Based
Session Format: Live Virtual Webinar with Q&A
Program Level: Intermediate to Advanced
Prerequisites: Basic familiarity with IRS compliance procedures recommended
Attendance Requirement: Required for live CPE credit
LIVE means you can attend the class in real time on the scheduled date and time.
The link to join the class will be shared with you 30 minutes to 1 hour before the class begins.
On-Demand means you can watch the recorded class at your convenience.
The link to access the class will be shared 48 hours after the commencement date of the live class.
You can let us know your preferred date to receive the link.
Note: Once the link is shared, you can access the class for three (3) days.
Web Download allows you to download the class recording for offline viewing.
The download link will be shared with you within 48 working hours after the commencement of the class.
An e-Transcript is a written text version of the entire class session.
It is useful for note-taking, revision, and quick reference.
The e-Transcript download link will be shared within 48 working hours after the commencement of the class.
This option includes: