Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Wednesday, May 1, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE/CPE webinar will provide tax attorneys, CPAs and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign information reporting forms, their associated penalties, and FBAR abatement requests. The panel will offer useful tools for compiling and submitting the appeal correspondence and documentation.


The IRS employs strict standards for determining whether a taxpayer qualifies for a penalty abatement for failure to file required foreign information returns and FBARs.

The U.S. Treasury Inspector General for Tax Administration (TIGTA) issued a report in recent years showing that IRS controls over penalties were deficient, leading to incorrect abatement in a large percentage of tested cases. As a result, the IRS has promised increased scrutiny over foreign penalty abatement requests.

IRS audits have not become more manageable. Once chosen, a taxpayer can expect to face a probing investigation, potentially leading to stiff penalties. Critical to navigating the FBAR and foreign information reporting forms appeals process is an understanding of the legal standards, the potential penalty level, arguments (legal and otherwise), and evidence to assemble. Counsel and advisers must prepare to present a comprehensive and cohesive case for taxpayers seeking to appeal their FBAR and other penalties.

Listen as our experienced panel of advisers provides a practical guide to navigating the process for handling penalty abatement denials. Attendees will receive an insider's look at how leading practitioners resolve complicated international controversies.



  1. Not Just the FBAR -- a review of the foreign reporting forms
  2. The Administrative Remedy Paths, Proactive and Reactive
  3. The Review Standards -- Willfulness and Reasonable Cause


The panel will review these and other key issues:

  • Recognize approaches to resolve international controversies
  • Identify the types of lesser-known foreign assets transactions that trigger significant penalty risks
  • Determine legal and practical issues that can erupt in these cases and approaches to mitigate those risks
  • Discuss the relevant law applied during audit and appeal


Hanson, Robert
Robert V. Hanson, Esq.

International Tax Attorney
Parent & Parent

Mr. Hanson is the lead attorney in the firm’s International Tax department. He received the CALI Academic...  |  Read More

Parent, Anthony
Anthony E. Parent

Founding Partner
Parent & Parent

Mr. Parent is the founding partner of his firm, and has a tremendous amount of success in opt-out audits and FBAR...  |  Read More

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