Tax Law Center Blog

The boundary between civil tax non-compliance and criminal tax exposure has never been more porous. As the Internal Revenue Service aggressively expands its enforcement footprint utilizing advanced data analytics, practitioners must be prepared to handle both complex international compliance structures and high-stakes criminal investigations.

For tax professionals, staying ahead of these shifts is vital to safeguarding both your clients and your professional practice.

We are pleased to announce that Parag Patel will be a featured speaker at the New Jersey Society of Enrolled Agents (NJSEA) Annual Conference. The full-day event is scheduled for June 10, 2026, at Brookdale Community College in Lincroft, New Jersey. Parag will deliver two separate, independent technical presentations designed to equip tax advisors with advanced defensive strategies.

Session 1: Criminal Tax: What Tax Professionals Need to Know

International information return omissions remain a primary target for automated IRS penalties and deep-dive audits. In this independent session, Parag will analyze the strict operational requirements of foreign trust reporting and how to manage historical non-compliance.

The presentation will focus heavily on:

• The Mechanics of Form 3520 and Form 3520-A: Navigating the dual-filing obligations under Section 6048 and the critical importance of trust-specific Employer Identification Numbers.
• The Substitute Filing Track: How to protect a U.S. owner when a foreign trustee refuses to cooperate, including the precise execution of a Substitute Form 3520-A.
• Defending Against Section 6677 Penalties: Implementing litigation-tested frameworks to secure penalty abatements through administrative reasonable cause petitions.

Session 2: Navigating Criminal Tax Investigations and Badges of Fraud

In a separate, dedicated presentation, Parag will shift focus to the procedural realities of federal criminal tax defense. As the IRS Criminal Investigation Division increases its scrutiny of domestic and offshore activities, understanding how a civil audit converts into a criminal prosecution is essential.

Key takeaways from this session will include:

• Identifying Badges of Fraud: Recognizing the precise administrative indicators that an IRS civil examination is transitioning into a parallel criminal investigation.
• The Voluntary Disclosure Decision Matrix: Analyzing when a client must utilize the IRS Voluntary Disclosure Practice (VDP) versus civil disclosure pathways, and the severe risks of making a non-willful certification under penalties of perjury when elements of willfulness exist.
• Constitutional and Evidentiary Protections: Managing special agents, understanding the limits of the Section 7525 practitioner privilege in criminal matters, and preserving the attorney-client privilege during a grand jury investigation.

Why Tax Professionals Must Attend

The NJSEA Annual Conference represents a premier gathering of the region’s top tax minds. Attending Parag’s independent sessions will equip Enrolled Agents, Certified Public Accountants, and tax attorneys with the technical knowledge required to spot high-risk international issues and confidently manage criminal tax exposure.

As a firm specializing exclusively in high-stakes tax controversy, civil audit defense, and criminal tax litigation, we are dedicated to supporting the broader professional tax community. We routinely collaborate with primary accountants and tax preparers to provide the specialized legal air support necessary to resolve complex, sensitive client controversies.

Learn more about how we can partner with your practice to resolve your client’s international or criminal tax issues. Contact us for a confidential, professional consultation.