Administrative Procedure Act and International Penalties: Timing Issues, Strategies for Challenging FBAR Penalties

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.

Ms. Liu concentrates her practice in areas of domestic and international tax. She has served as lead or co-counsel in federal courts throughout the United States involving criminal tax matters, tax controversies, employment tax controversies, SEC securities litigation, and post-employment covenants not to compete (including the successful litigation in district court for the Northern District of Georgia proceeding of first impression adjudicating the enforceability of a forum select clause, and covenant not to compete controversy. This case was named in the California Labor and Employment Bulletin as one of the top ten California Trade Secrets and Unfair Competition Developments). Ms. Liu has successfully resolved hundreds of serious tax matters for business and high net worth individuals, both in court and through negotiations with the IRS. She has assisted many clients in tax controversy matters at audit and administrative appeals before the IRS and state tax authorities. Ms. Liu also has significant experience in representing clients before the IRS programs offered to taxpayers to correct their past non-compliance. She has represented many clients through the IRS voluntary disclosure program and Streamlined Filing Compliance Procedures.