Tips for Handling Business Clients with Unpaid Payroll Taxes


Shaking Hands-1

Envision a scenario where your business client has not paid their payroll taxes for several months, or even longer.  Times were tough and they skipped several periods of withholding for their employees.  This has resulted in large sums of money not paid, and the situation has snowballed quickly.  The client fears they are in danger of losing their business, or at risk of being shut down by the IRS.  How do you stop this debt from accumulating further with every pay period before it becomes an avalanche that wipes out your client’s entire business?  How do you quickly help your client get back into compliance?  How do you best deal with IRS field agents and revenue officers (ROs) and give them a reason to work with you to settle this situation.  After all, we all want the same thing: To work together so the IRS can close this case in the fastest, most equitable way possible while bringing this business client back into compliance.   

On Monday Nov. 7 from 1 PM to 2 PM, Venar Ayar, JD, LLM will explain how to do exactly that during a special online webinar.  Join him as he pulls back the curtain to give you a behind-the-scenes look at how the IRS field office works in delinquent payroll tax cases.  Plus, get his best practice tips, acquired over his years of tax law experience, on how to handle the revenue officers (ROs) and help them (and your business client) resolve these situations swiftly, fairly and equitably to everyone’s satisfaction. 

You will receive expert advice on:

  • How to best respond to Federal Tax Deposit (FTD) alerts, which is the automatic mechanism that warns the IRS something is amiss and generates an “immediate assignment” of a revenue officer to conduct a pre-contact investigation, prior to the in-person visit that usually ensues.
  • How the IRS deals with “Repeaters” and “Pyramiding Taxpayers” who may have several payroll tax delinquencies and violations.
  • The Trust Fund Recover Penalty (TFRP) (IRC §6672), which the IRS uses to encourage and enforce compliance with IRC §7501.
  • How the IRS defines its terms, including who qualifies as the “responsible person” and what qualifies as “willfully failing” to collect these trust fund taxes.
  • How the IRS ROs can examine all corporate documents such as articles of incorporation, by-laws, payroll records, bank records, cancelled checks, tax returns, and even conduct witness interviews to help resolve and collect these TFRPs.
  • How Third-Party Liability (IRC §3505) is determined by the IRS.
  • Enforcement Proceedings, in general (Hand-Delivery of Letter 903:  You Haven’t Deposited Federal Employment Taxes).
  • Civil Enforcement (IRC §7402).
  • Why Criminal Enforcement (IRC §7202) Felony Prosecution are cases usually won by the government.

Take your knowledge to the next level by reserving your place for this upcoming webinar: Tips on Dealing with Revenue Officers for Unpaid Payroll Taxes.  

Source: MICPA

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