EB International Tax Examinations and Investigations | E2030617

Date :
June 20, 2017 8:00 AM - 9:00 AM
Location :
East Bay Area
Facility :
Sunrise Bistro
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Level of Difficulty :
Member Price :
Nonmember Price :
CPE Credits :
CPE 1.00
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What to do when your client is the subject of a civil examination or criminal investigation and has offshore compliance issues?
This informative 1-hour program will cover the basic steps that you should take when your client is the subject of a civil examination or criminal investigation. The program will review and discuss the factors that the IRS considers in evaluating whether a case is criminal, the international reporting obligations for green card holders, individuals who pass the substantial presence test, and nonresident aliens, and the potential civil and criminal penalties that may exist for clients who are have compliance issues.


  • What factors the IRS considers in evaluating whether a case is civil or criminal 
  • An understanding of the international tax reporting obligations for green card holders, H1-B visa holders, and nonresident aliens
  • The civil and criminal risks to clients who are not in compliance with the Internal Revenue Service

Major Subjects:

  • Civil and criminal tax penalties
  • International reporting obligations
  • Foreign Account Tax Compliance Act
  • Common sense steps to take when representing a client before the Internal Revenue Service

Advanced Prep:


Misc. Information:

Level of Difficulty:
Field of Interest:
Designed For:
CPAs, attorneys, financial planners, enrolled agents, professional staff


Steven L. Walker, Esq.

Steven L. Walker is a tax attorney in San Jose. His practice focuses on representing individuals and businesses in tax controversies with governmental agencies including tax examinations, investigations, audits and litigation in U.S. Tax Court and federal district courts. He also handles international tax planning and compliance issues. Walker was the chair of the Taxation Section of the State Bar of California for 2014-2015. He also is an adjunct professor at the University of San Francisco School of Law in the master of laws in taxation program, where he teaches tax fraud and federal tax procedure.

Walker is a former IRS trial attorney at the Office of Chief Counsel, IRS, where he furnished legal advice and representation to the IRS on all matters relating to the administration and enforcement of the internal revenue laws, including audits, administrative appeals, collections and federal and state litigation. Walker also worked at the California Franchise Tax Board. He is admitted to practice before the United States Tax Court, has 18 civil tax trials and numerous published United States Tax Court cases, and is a recipient of the IRS Special Act Award.

Walker was invited to Washington, DC in 2016 by the Taxation Section, State Bar of California, to present a position paper regarding the Foreign Account and Tax Compliance Act (FATCA). In 2014, Walker presented a paper topic regarding the modification and compromise of restitution orders in criminal tax cases. In 2012, he presented a paper topic regarding the tax treatment of foreign retirement accounts, and in 2010, he presented a paper topic regarding a significant tax issue facing businesses in California. The papers were presented to the IRS, U.S. Treasury Department, U.S. Tax Court, and Congressional personnel.

Walker is a former partner of a major international law firm in Palo Alto and former associate general counsel of a publicly-traded Silicon Valley company. Walker holds a bachelor’s degree in electrical engineering from the University of California, Davis, and a juris doctor degree and master of laws in taxation from McGeorge School of Law, University of the Pacific.

No Agenda or Materials posted.