Administrative Procedure Act and International Penalties
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will provide tax counsel and advisers with a thorough and practical guide to strategies for administrative challenges and defenses against international penalty assessments under the Administrative Procedure Act (APA). The panel will contrast the penalty structures between FBAR and other foreign-related information filings and focus on remedies available under the APA for challenging FBAR penalties.
Outline
- Significance of international penalties under Title 26 and Title 31
- Potential application of the APA to international penalties
- Strategic considerations for determining whether to make an APA argument
- Timing issues
- Designing an APA strategy
Benefits
The panel will discuss these and other topics:
- Why consider bringing an APA claim.
- What government defenses should tax counsel consider before bringing an APA challenge to an international penalty.
- What impact does an administrative claim under the APA have on an international penalty?
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Kerrin N.T. Liu
Partner
Diosdi & Liu
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations,... | Read More
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court. Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.
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Cannot Attend September 18?
Early Discount (through 08/22/25)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.
