About the Course
Introduction
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.
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.
Presented By
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.
Ms. Ziering represents individual and entity taxpayers in civil and criminal tax matters before taxing authorities and enforcement agencies, including the Internal Revenue Service, the Department of Justice, and state tax authorities. She has represented clients in federal and state courts, including the United States Tax Court and the Court of Federal Claims. Ms. Ziering assists clients in all stages of the tax controversy and litigation cycle. She is a well-regarded member of the tax law community, serving as the Chair of the Court Practice and Procedure Committee for the American Bar Association, Section of Taxation. Ms. Ziering is a sought-after speaker and writer on topics related to tax controversy, tax litigation, and tax reporting compliance. She is the co-author of the original and new edition of Bloomberg BNA Tax Management Portfolio, “Report of Foreign Bank and Financial Accounts,” which is scheduled for publication in 2025. In addition, Ms. Ziering was a co-author of the Center for Taxpayer Rights’ amicus curiae brief in the Supreme Court of the United States case Bittner v. United States, which was quoted in the Supreme Court’s opinion.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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CPE credit is not available on recordings.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Thursday, September 24, 2020
- schedule
1:00 p.m. ET./10:00 a.m. PT
- 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
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?
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.
BARBRI, 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.
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 Barbri-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 .
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