Submitting a Whistleblower Claim to the United States Internal Revenue Service

This comprehensive program examines the IRS whistleblower program's evolution and current framework for reporting tax fraud and violations. The course traces the development of tax whistleblower laws from the Revenue Act of 1862 through modern enforcement initiatives, providing detailed analysis of filing requirements and award calculations. Through examination of significant cases, including the UBS whistleblower scandal, participants will gain practical insights into successful whistleblower strategies.

Designed for tax attorneys, compliance professionals, and whistleblower counsel, this program provides essential guidance on preparing Form 211 submissions and navigating foreign account reporting requirements. Participants will learn about the program's scope and effectiveness, including analysis of the current tax gap and the role whistleblowers play in enforcement efforts.

This program is presented by Neal A. Roberts, who brings extensive experience in tax whistleblower representation and complex financial fraud investigations.

Learning Objectives:

1. Analyze IRS whistleblower eligibility requirements and award criteria under 26 USC §7623 to effectively evaluate potential claims
2. Implement strategies for preparing comprehensive Form 211 submissions that meet statutory requirements for foreign account reporting and transfer pricing violations
3. Evaluate complex tax fraud schemes through examination of major enforcement actions and whistleblower cases
4. Apply best practices for documenting tax violations while maximizing potential whistleblower awards under the established statutory framework