Course Description

This advanced training session led by Michael DeBlis, explores the critical juncture where civil tax audits evolve into criminal investigations—an area fraught with risk for financial professionals, tax advisors, and legal counsel. Attendees will gain insight into how to detect early red flags in so-called “eggshell” and “reverse eggshell” audits, understand the role of IRS Criminal Investigation (CI), and develop practical strategies to protect clients and organizations.

The course also addresses the tactical use of Kovel arrangements to extend privilege to non-lawyer professionals and outlines how to prepare for parallel civil and criminal proceedings. This training is essential for professionals involved in tax planning, audit defense, or financial crime compliance.

Agenda:

• Identifying warning signs in “eggshell” and “reverse eggshell” audits

• Understanding the role and authority of IRS Criminal Investigation (CI)

• Strategies to minimize risk during civil audits that may turn criminal

• Leveraging Kovel arrangements to protect communications and analysis

• Preparing for and managing parallel civil and criminal proceedings