About the Course
Introduction
This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant international information reporting forms (including tax and FBAR filings)their associated penalties, and the process of administratively requesting abatement of penalties. The panel will offer useful tools for compiling and submitting the appeal correspondence and documentation.
Description
The IRS employs strict standards for determining whether a taxpayer qualifies for penalty abatement for failure to file required international information returns and FBARs.
Penalties for international reporting issues arise from two main sources: IRS audits and taxpayers filing late (or perceived as late) international information returns. IRS audits often attempt to impose maximum penalties for various strategic reasons. And IRS campuses often systemically penalize perceived late submissions to increase tax revenue. Critical to navigating penalties arising from FBAR and international information returns is the administrative appeals process involving the Independent Office of Appeals.
Listen as our experienced panel of advisers provides a practical guide to navigating the process for handling penalty appeals. Attendees will receive an insider's look at how leading practitioners approach complicated and often enormous international reporting penalties.
Presented By
Mr. Fallahi is an Attorney at Law whose practice focuses on domestic and international tax controversy, IRS Appeals, foreign information reporting, regulatory compliance, and complex cross-border tax matters. He represents individuals, physicians, closely held businesses, and multinational clients before the Internal Revenue Service (IRS), the IRS Independent Office of Appeals, the U.S. Department of the Treasury, the Financial Crimes Enforcement Network (FinCEN), and the Office of Foreign Assets Control (OFAC). Mr. Fallahi has extensive experience advising and representing taxpayers in matters involving offshore compliance, foreign information return penalties, IRS Appeals, reasonable cause defenses, and voluntary disclosure matters arising from international reporting obligations. He regularly counsels clients on FBAR, FATCA, Forms 3520 and 8938, and other U.S. international information reporting requirements. has represented clients from more than 50 countries in sophisticated cross-border tax, reporting, and regulatory matters. Mr. Fallahi has lectured on international tax compliance, IRS enforcement, foreign information reporting, tax controversy, and cryptocurrency taxation. He has completed executive education programs at Harvard Law School in Negotiation and Leadership and at the MIT Sloan School of Management in Blockchain Technologies, further strengthening his practice in cryptocurrency taxation and digital asset compliance.
Mr. Price's legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Mr. Price served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Mr. Price has had unique experience with tax controversy and tax administration.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Thursday, September 24, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Common international information returns and common penalties
II. Common international reporting mistakes
III. Requesting penalty abatement
IV. Administrative penalty appeals – best practices, common timelines, and preserving issues for potential litigation
V. Collection Due Process as a path to challenge Title 26 international information return penalties
VI. Concepts of intent and relevant standards including reasonable cause, negligence, gross negligence, non-willful conduct, recklessness, willful blindness, and willful reporting violations
VII. ADR in IRS penalty disputes: Fast Track Mediation and Post Appeals Mediation
The panel will review these and other key issues:
- Recognize approaches to resolve international information return penalties
- Identify lesser-known reporting pitfalls and common mistakes
- Determine common legal and practical issues arising in these cases and strong arguments to counter common government positions
- Discuss the relevant law for international information return penalty appeals
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