FBAR Investigations and Litigation | CLE/CPE Course

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Course Details

Course Information

smart_display Format
Live Online with Live Q&A
signal_cellular_alt Difficulty Level
Intermediate
work Practice Area
Tax Law

Date & Time

event Date
Thursday, July 10, 2025
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 webinar will provide tax counsel and advisers a critical analysis of FBAR investigations, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, recent IRS guidance and relief for certain taxpayers, and new cases with issues of first impression as such relate to FBAR compliance.

Faculty

Leo Parmegiani

Partner

PKF O'Connor Davies, LLP

Mr. Parmegiani has considerable expertise in a broad range of tax specialty areas, including the hospitality and real estate industries, both domestic and international business investments, sales and use tax, C Corporations, S Corporations, Partnerships, LLCs and REITs, and state and local tax issues. He has worked extensively with high net worth individuals, including United States taxpayers living abroad and foreign nationals living in the United States and advises foreign groups in establishing domestic business operations. He has spent most of his career with Big Four and other large accounting firm networks, and was also Director of Tax for the New York office of another network for eight years. He frequently contributes tax articles to the PKF International Tax Alert and presents at the annual PKF International Tax Conference.

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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 noncompliant taxpayers, focusing on (1) reporting issues on foreign accounts, assets, and investments, and (2) foreign income generated from foreign businesses, gifts, inheritances, mutual funds, and other passive investments.

Possessing an in-depth understanding of international tax 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 the most complex aspects of international tax compliance, including FBAR filing and reporting requirements, navigating assessments and litigation, and the evolution of the "non-willful" standard, as well as managing administrative appeals, the federal district court, and U.S. Court of Federal Claims litigation.

Outline

I. Navigating the FBAR investigation and assessment process

II. Critical compliance issues and resolution options

III. Penalties and designing FBAR defense strategy

IV. Litigation; recent cases and IRS enforcement actions

Benefits

The panel will review these and other key issues:

What are the international tax compliance issues and pitfalls to avoid?
What foreign reporting forms are subject to foreign tax reporting penalties?
How can you minimize the risk of audits?
What are the penalty structures for non-willful and willful failure to file?
What is the IRS penalty abatement decision-tree model, and how does it apply to requests to abate foreign tax penalties?
What are the standards for "reasonable cause" abatement?
What are the critical challenges of FBAR controversies, administrative appeals, and the district court and the court of federal claims litigation?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

Identify international tax compliance issues and pitfalls to avoid
Recognize foreign reporting forms that are subject to foreign tax reporting penalties
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

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.