Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course 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.
Outline
- Not just the FBAR: a review of the foreign reporting forms
- The administrative remedy paths: proactive and reactive
- The review standards: willfulness and reasonable cause
Benefits
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
Faculty
Guy Glaser
Attorney
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
Mr. Glaser has over 30 years of tax experience with the IRS. He spent the first twenty years as a Senior Trial Attorney for the Service’s Office of Chief Counsel’s Small Business and Self-Employed (SBSE) Division. For the next 10 years, he served as the Laguna Niguel Associate Area Counsel for the IRS Office of Chief Counsel’s Large Business and International (LB&I) Division. He also worked a 6-month stint as a Special Assistant United States Attorney for the Office of the United States Attorney, Central District of California, Tax Division in Los Angeles. As a Senior Trial Attorney for the IRS Office of Chief Counsel’s Small Business and Self-Employed Division, Mr. Glaser was responsible for providing legal advice to the IRS on tax audits and collection matters. He also assisted in implementing the IRS’s Offshore Compliance Initiative and the Offshore Credit Card Program. He served as one of the initial eleven nationwide IRS Office of Chief Counsel FBAR Coordinators
Close
Robert V. Hanson, Esq.
Tax Manager
Moore Doeren Mayhew
Mr. Hanson’s practice focuses on individuals and organizations with offshore assets and international tax... | Read More
Mr. Hanson’s practice focuses on individuals and organizations with offshore assets and international tax exposure. He represents clients during examinations, administrative appeals of FBAR and international information reporting form penalties, and offshore voluntary disclosures, as well as providing advice to taxpayers with foreign businesses regarding possible U.S. tax exposure. Prior to joining the firm, Mr. Hanson worked with low income taxpayers at the University of Connecticut School of Law.
Close