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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:

  • Preponderance of Evidence
  • Beyond a Reasonable Doubt

Understanding the IRS Criminal Investigation Division (IRS-CI)

Roles and responsibilities of:

  • Revenue Agents
  • Revenue Officers
  • IRS-CI Special Agents

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:

  • Underreported income
  • Payroll tax noncompliance
  • Offshore accounts
  • Foreign asset reporting
  • Cryptocurrency and digital assets

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

Credits & Additional Information

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

Frequently Asked Questions (FAQs)

What does LIVE mean?

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.

What does On-Demand mean?

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.

What is Web Download?

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.

What is an e-Transcript?

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.

What does LIVE + e-Transcript include?

This option includes:

  • Access to the live class, and
  • A downloadable e-Transcript provided within 48 working hours after the class.