After the FBAR Overhaul: Foreign Account Reporting Enforcement
Preparing for IRS Exams, Potential Penalties, Administrative Appeals or Litigation
IRS released new FBAR form, penalties manual on Nov. 1
Recording of a 110-minute CPE webinar with Q&A
This teleconference will prepare advisors and taxpayers for the next wave of IRS enforcement and potential penalties, following conclusion of the 2011 offshore voluntary disclosure initiative.
- Review of potential FBAR civil penalties
- Non-willful violations
- Willful failure to file
- Knowingly and willfully filing false report
- Anticipated timeline of IRS enforcement going forward
- Post-OVDI oversight
- Exams involving FBAR
- Exams involving FATCA return
- Preparing for an audit with foreign information return penalties in mind
- Preparing for an administrative appeal
- Preparing for litigation
The panel will explore these and other relevant topics:
- Anticipated IRS focus of its enforcement resources after conclusion of the last OVDI.
- Good faith, reasonable cause and other general defenses against penalties.
- Approaches to consider in preparing for related IRS exams, administrative appeals and litigation.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Hochman Salkin Rettig Toscher & Perez
He has a broad-based tax practice covering federal and state income taxes and estate, employment, excise, sales and... | Read More
He has a broad-based tax practice covering federal and state income taxes and estate, employment, excise, sales and property tax matters. He previously headed the West Coast tax litigation practice for another firm and also worked as a trial attorney in the U.S. Justice Department's Tax Division.Close
John M. Colvin
Colvin & Hallett
Mr. Colvin's practice emphasizes federal tax controversies and white-collar criminal defense. He is a frequent... | Read More
Mr. Colvin's practice emphasizes federal tax controversies and white-collar criminal defense. He is a frequent speaker on tax topics and chairs the ABA Taxation Section's Subcommittee for Legislative and Administrative Developments.Close
Rosenberg Martin & Greenberg
She represents business clients in federal and state tax controversies and litigation, and in criminal tax cases. She... | Read More
She represents business clients in federal and state tax controversies and litigation, and in criminal tax cases. She represents clients regularly before the IRS and federal tax and civil courts.Close