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

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

Tuesday, April 20, 2021

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, March 26, 2021

or call 1-800-926-7926

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 penalty abatement for failure to file required foreign information returns and FBARs.

The U.S. Treasury Inspector General for Tax Administration 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 understanding 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


Glaser, Guy
Guy Glaser

Brager Tax Law

Mr. Glaser has over 30 years of tax experience with the IRS. He spent the first twenty years as a Senior Trial Attorney...  |  Read More

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

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