BarbriSFCourseDetails
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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 Preparer

Date & Time
  • event Date

    Friday, June 20, 2025

  • schedule Time

    1:00 PM E.T.

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$197.00
CPE
ALL

This webinar will analyze the most recent and relevant court cases affecting international taxpayers. Our panel of foreign tax veterans will detail the status of recent and notable cases and offer insights for handling common international tax and compliance problems.

Faculty

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. 

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Robert Horwitz
Principal
Hochman Salkin Toscher Perez, PC

Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year.  Mr. Horwitzwas previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section. Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board. He has been a speaker on tax matters at the UCLA Tax Controversy Institute, the Annual Meeting of the Taxation Section of the California Bar and the California State Bar Annual Meeting. Mr. Horwitz has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the Federal Lawyer (the publication of the Federal Bar Association), and the California Tax Lawyer.  His monograph in “Responsible Persons and Fiduciary Liability” was published in the Proceedings of the New York University 75th Institute on Federal Taxation.  Mr. Horwitz was an invited delegate to the 2015 U.S. Tax Court Judicial Conference.  He is a member of the Planning Committee of the UCLA Tax Controversy Institute. Mr. Horwitz is a member of the bar in California and in Illinois. He is admitted to practice in the United States District Courts for the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018.

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Melissa Briggs
Principal
Hochman Salkin Toscher Perez, PC

Description

International tax practitioners and advisers need to stay abreast of the continually increasing number of cases and matters brought against multinational taxpayers by the U.S. government. Most familiar are the challenges brought against taxpayers for failure to file an FBAR to report aggregate foreign holdings over $10,000 as required under the Bank Secrecy Act. Although advisers are clear that there is a $10,000 penalty for noncompliance, determining how it is applied is not clear.

It has been troubling that the IRS can collect penalties in excess of a taxpayer's account balance for late and misfiled FBAR reports. Recently, the Eleventh Circuit decided in U.S. v. Schwarzbaum that certain willful FBAR penalties violate the Eighth Amendment's excessive fines clause. This ruling created a split with the First Circuit Court decision in U.S. v. Toth that these penalties are not subject to the Eighth Amendment clause.

Astounding FBAR penalties are not the only worry of international tax advisers. Challenging international taxpayers can be a lucrative pursuit. Penalties for failing to report foreign distributions by timely filing Form 3520 are the greater of $10,000 or 35 percent of the distribution. Additionally, the IRS continues to aggressively pursue Accidental Americans and deny passports for unpaid taxes as well. International tax practitioners need to stay abreast of the status of the most recent international tax cases to properly advise multinational clients.

Listen as our astute panel of international tax experts reviews the most current and pertinent international tax cases so that practitioners understand how these cases affect taxpayers with foreign ties.

Outline

  1. International tax disputes
  2. FBAR cases
    1. Noncompliance
    2. Willful vs. non-willful
    3. Excessive fines
    4. Addressing noncompliance
  3. FBAR pursuits after the death of taxpayer
  4. Failure to file Form 3520 for transactions with foreign trusts and certain foreign gifts
  5. Accidental Americans
  6. Other cases

Benefits

The panel will cover these and other critical issues:

  • Best practices for handling non-filing of FBARs
  • Differences in rulings by circuit courts in applying FBAR penalties
  • Distinguishing willful vs. non-willful FBAR violations
  • Current cases against estates for FBAR penalties of a deceased taxpayer

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify which penalties can be assessed to beneficiaries
  • Determine steps multinational taxpayers can take to lessen court challenges
  • Decide how the state of residence could influence potential penalties
  • Ascertain which taxpayers could be subject to excessive fines for FBAR 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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.

IRS Approved Provider

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