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Course Details

Course Information
  • smart_display Format

    On-Demand

  • 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.


  • Live Online


    On Demand

$347.00

This course is $0 with these passes:

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

Yevgeny Antonov
Director
PKF O'Connor Davies, LLP

Mr. Antonov has eight years of experience in federal, state and international income tax. He has worked with multinational businesses and high net-worth individuals, including U.S. subsidiaries of foreign corporations and partnerships. Mr. Antonov provides support on U.S. entity formation and dissolution issues, state and local tax, tax treaty and expat tax issues. He has represented corporate and individual clients before the Internal Revenue Service and state tax departments in connection with tax examinations, and tax controversies.

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Christopher Hall
Director, Global Tax Mobility Services Practice Lead
PKF O'Connor Davies, LLP

Mr. Hall is a Director, Global Tax Mobility Services Practice Lead at PKF O’Connor Davies. 

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Thomas Kinder
Director
PKF O'Connor Davies, LLP

Mr. Kinder has more than seven years of experience in public accounting. His expertise is in international tax consulting for both corporate and individual taxpayers. Mr. Kinder also has experience in the international sector focusing on cross-border transactions, internal reorganizations and M&A transactions. He contributes articles to the organization’s Thought Leadership series, as well as to outside professional publications. 

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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?