On August 30, 2022, the US Department of Justice issued a press release reiterating that civil and criminal employment tax enforcement is among the Tax Division’s highest priorities. The IRS and DoJ have stepped up criminal enforcement against employers who fail to meet their employment tax obligations. This program will review employment tax obligations, the Trust Fund Recover Penalty which comprises employers’ personal liabilities for their failure to collect and pay over wages withheld from their employees and their employees’ share of employment tax – and criminal tax liability for employment tax failures.
Michele F.L. Weiss, Senior Counsel at Holtz, Slavett & Drabkin, is a CA state bar certified specialist in tax law and a former IRS Counsel attorney. She helps businesses, business owners and investors resolve their civil and criminal tax disputes with the IRS and state tax agencies - FTB, EDD, BoE, and CDTFA - in examinations, appeals, litigation, criminal and collection defense. She has expertise in many substantive and procedural tax issues including penalty abatement, payroll and employment tax, offshore tax compliance and sensitive disclosure matters, trust matters, qualified contributions, R&D and ERC credits, cryptocurrency, and non-profit matters. She provides tax counsel in business litigation and bankruptcy matters.
Gary M. Slavett has been a California licensed attorney since 1996 and has over 20 years of experience in the practice of tax law. Gary’s practice focuses on tax controversy matters including issues related to Foreign Bank Accounts & FBAR penalties, criminal tax defense, tax litigation, tax audit representation, and tax administrative appeals. Gary also handles matters related to the Bank Secrecy Act and Administrative and Civil Forfeitures. Gary frequently represents his clients before the United States Tax Court, U.S. District Court, Internal Revenue Service, United States Attorneys Office, California Franchise Tax Board, State Board of Equalization, and the Employment Development Department. Gary was a Senior Trial Attorney for the Internal Revenue Service, Office of Chief Counsel. As an IRS attorney, Gary represented the IRS in U.S. Tax Court and provided legal advice to IRS personnel. After leaving the IRS, Gary joined Deloitte & Touche’s Tax Controversy Group in Los Angeles. At Deloitte, Gary represented Deloitte’s clients before the IRS and state taxing authorities. Clients included Fortune 500 companies from the banking, healthcare, and toy industries, a professional sports team, a popular television personality, and regional real estate and construction firms.