BarbriSFCourseDetails
  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process

$347.00

This course is $0 with these passes:

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Description

The IRS employs strict standards for determining whether a taxpayer qualifies for penalty abatement for failure to file required foreign information returns and FBARs.

In recent years, the U.S. Treasury Inspector General for Tax Administration issued a report showing that IRS controls over penalties were deficient, leading to incorrect abatement in a large percentage of tested cases. As a result, the IRS has increased scrutiny over foreign penalty abatement requests.

IRS audits have not become more manageable. Once chosen, a taxpayer can expect to face a probing investigation, potentially leading to stiff penalties. Critical to navigating the FBAR and foreign information reporting forms appeals process is understanding the legal standards, the potential penalty level, arguments (legal and otherwise), and evidence to assemble. Counsel and advisers must prepare to present a comprehensive and cohesive case for taxpayers seeking to appeal their FBAR and other penalties.

Listen as our experienced panel of advisers provides a practical guide to navigating the process for handling penalty abatement denials. Attendees will receive an insider's look at how leading practitioners resolve complicated international controversies.

Presented By

Jonathan Kalinski
Principal
Hochman Salkin Toscher Perez, PC

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters.  Prior to joining the firm, he served as a trial attorney with the IRS Office of Chief Counsel litigating Tax Court cases and advising revenue agents and revenue officers on a variety of complex tax matters. 

Edward M. Robbins
Principal
Hochman Salkin Toscher Perez, PC

Mr. Robbins has considerable experience handling sensitive issue civil examinations and administrative appeals, civil trials and appeals defending complex criminal tax investigations, civil trials and appeals, and defending criminal tax prosecutions (jury and non-jury).  He has successfully handled literally hundreds of matters involving previously undeclared interests in foreign financial accounts and assets.





Representation  currently includes Federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy  administrative matters before the Internal Revenue Service, the California Franchise Tax Board, the California State Board of Equalization, California Employment Development Department and various state taxing authorities of individuals, business enterprises, partnerships, limited liability companies, and corporations. Representation also includes individuals and organizations involved as targets, subjects, or witnesses in Federal and California criminal investigations and related grand jury and pre-trial proceedings, trials and appeals.  In the world of civil tax and criminal tax investigations, Mr. Robbins has truly touched every conceivable issue during his lengthy and successful career.

Michel R. Stein
Principal
Hochman Salkin Toscher Perez, PC

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. 

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Wednesday, October 4, 2023

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Not just the FBAR: a review of the foreign reporting forms
  2. The administrative remedy paths: proactive and reactive
  3. The review standards: willfulness and reasonable cause

The panel will review these and other key issues:

  • Recognize approaches to resolve international controversies
  • Identify the types of lesser-known foreign assets transactions that trigger significant penalty risks
  • Determine legal and practical issues that can erupt in these cases and approaches to mitigate those risks
  • Discuss the relevant law applied during audit and appeal

Learning Objectives

After completing this course, you will be able to:

  • Ascertain approaches to resolve international controversies
  • Identify the types of lesser-known foreign assets transactions that trigger significant penalty risks
  • Recognize relevant law applied during audit and appeal
  • 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+ law or accounting firm experience at mid-level within the organization, interpreting or preparing complex tax forms and schedules for domestic and multinational businesses; supervisory authority over other attorneys/tax staff. Knowledge and understanding of foreign information filing requirements and penalties for non-compliance; familiarity with IRS processes for penalty abatement requests and appeals of IRS penalties.

BARBRI 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.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .