FBAR Investigations and Litigation | CLE/CPE Course

BarbriSFCourseDetails

Course Details

Course Information

smart_display Format
On-Demand
signal_cellular_alt Difficulty Level
Intermediate
work Practice Area
Tax Law

Date & Time

event Date
Thursday, September 24, 2020
schedule Time
1:00 p.m. ET./10:00 a.m. PT
timer Program Length
90 minutes

Credit Information

This 90-minute webinar is eligible in most states for 1.5 CLE credits.
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00

CLE

CPE

ALL

This CLE/CPE course will provide tax counsel and advisers a critical analysis of FBAR examination, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, IRS guidance and relief for certain taxpayers, and new cases with issues of first impression relating to FBAR compliance.

Faculty

Zhanna A. Ziering

Member

Moore Tax Law Group, LLC

Ms. Ziering offers guidance to individual and corporate clients who require sophisticated tax advice concerning their domestic tax issues, offshore assets, and U.S. reporting requirements. Clients rely on her deep knowledge of tax controversies and tax litigation, as well as her experience with related civil, criminal, and regulatory proceedings. She represents both individuals and corporations before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators.

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James Dawson

Partner

Holland & Knight LLP

Mr. Dawson is a highly experienced tax litigator and business advisor with extensive knowledge resolving Internal Revenue Service (IRS) controversies in audit, appeals and litigation. His practice focuses on representing corporations and individual taxpayers in tax controversy and tax litigation matters.

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Description

The IRS is aggressively enforcing compliance with U.S. tax rules and foreign accounts compliance. This is particularly true in the case of failure to file a FinCen Form 114 (FBAR), where the IRS has had several high-profile court victories upholding penalties for willful failure to file.

Taxpayers with international tax reporting obligations suffer from rigorous compliance and enforcement efforts and overly complicated rules and regulations. The IRS is increasingly more effective at identifying non compliant taxpayers focusing on (1) reporting issues with respect to foreign accounts, assets, and investments, and (2) foreign income generated from foreign businesses, gifts, inheritances, mutual funds, and other passive investments.

Significant FBAR penalties, in particular, had been a powerful enforcement tool for the IRS. Possessing an in-depth understanding of FBAR filing rules and regulations will assist counsel and tax advisers in helping taxpayers maintain compliance and avoid FBAR investigations that may result in severe civil and criminal penalties.

Listen as our panel explains FBAR filing and reporting requirements, navigating FBAR examination and litigation, the evolution of the "non-willful" standard, and managing administrative appeals, the federal district court, and U.S. Court of Federal Claims litigation.

Outline

Critical compliance issues and resolution options
Navigating the FBAR examination and assessment process and administrative appeals
Penalties and FBAR defense strategy
Litigation; recent cases and IRS enforcement actions

Benefits

The panel will review these and other key issues:

What are the standards for "reasonable cause" abatement?
What are the critical challenges of FBAR controversies, administrative appeals, the district court, and the court of federal claims litigation?
Why does the APA provide possible grounds for defending against FBAR penalty assessments that are not available to taxpayers challenging other IRS foreign-related penalties?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

Understand FBAR penalty structures for non-willful and willful failure to file
Ascertain the standards for "reasonable cause" for abatement
Identify critical challenges of FBAR controversies, administrative appeals, the district court, and the court of federal claims litigation
Understand why the APA provides possible grounds for defending against FBAR penalty assessments that are not available to taxpayers challenging other IRS foreign-related penalties

Field of Study: Taxes
Level of Knowledge: Intermediate
Advance Preparation: None
Teaching Method: Seminar/Lecture
Delivery Method: Group-Internet (via computer)
Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other attorneys or accountants. Specific knowledge and understanding of foreign asset information reporting requirements, particularly FATCA and FBAR/FinCen 114; familiarity with IRS audit procedures in examining foreign tax reporting, familiarity with voluntary disclosure programs.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.