Interested in training for your team? Click here to learn more

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 program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, October 4, 2023

Recorded event now available

or call 1-800-926-7926

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.


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

In recent years, the U.S. Treasury Inspector General for Tax Administration issued a report 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 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


Kalinski, Jonathan
Jonathan Kalinski

Hochman Salkin Toscher Perez

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including...  |  Read More

Robbins, Jr., Edward M.
Edward M. Robbins, Jr.

Hochman Salkin Toscher Perez

Mr. Robbins has considerable experience handling sensitive issue civil examinations and administrative appeals, civil...  |  Read More

Stein, Michel
Michel R. Stein

Hochman Salkin Toscher Perez

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video