Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and Appeals
Recording of a 90-minute CLE/CPE webinar with Q&A
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, starting with an understanding of the major foreign information reporting forms, and the associated penalties. The panel will cover foreign information and FBAR abatement requests, and will offer useful tools to compiling and submitting the appeal correspondence and documentation.
- Not just the FBAR — Review of foreign reporting form
- The common forms.
- The penalty for not filing
- Statute of limitations (ASED) issues
- Appeals Forums- both administrative, and in court
- The Reasonable Cause standard for foreign reporting penalties
- Winning exam strategies
- Typical traps
- Knowing when you have a winning appeal
- Handling OVDP Opt Outs, Streamlined Submissions, and FBAR Audits
- OVDP - Submissions down.
- Streamlined Audits -- not common as far as we see
- Transitional Requests -- Success and Denial, Then what?
- Opt Out and removal Interviews, Approach and Issues
- FBAR Penalties in Audit
Attendees will get an inside look on how some of the most complicated international controversies are successfully resolved by leading practitioners in the field and learn the types of lesser-known foreign assets transactions that trigger significant penalty risks. They will also learn the common legal and practical issues that routinely erupt in these cases and what can be done to mitigate those risks.
Anthony E. Parent
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
Mr. Parent is the founding partner of his firm, and has a tremendous amount of success in opt-out audits and FBAR appeals. He represents U.S. taxpayers around the globe. He give numerous trainings on video and podcasts. He is a published writer, including The IRSMedic blog. He is quoted on tax issues in the national broadcast media. In 2012, he co-authored a business bestseller compilation Protect & Defend. He is currently finishing his first solo effort: IRS Confidential.Close
Dennis N. Brager, Esq.
Brager Tax Law Group
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and... | Read More
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and tax controversy matters. Before founding the Brager Tax Law Group, a Los Angeles-based tax litigation and tax controversy law firm, he was a senior trial attorney for the Internal Revenue Service’s Office of Chief Counsel. Since 2008 he has represented several hundred clients with offshore accounts. He also represents clients on a variety of issues, including criminal and civil tax fraud, tax audit and appeals, payroll and sales tax problems, tax preparer penalties, innocent spouse defenses, offers in compromise, installment payment agreements, Office of Professional Responsibility (“OPR”) defenses and more.Close
Robert 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
Mr. Hanson is the lead attorney in the firm’s International Tax department. He received the CALI Academic Excellence Award in International Tax Policy as well as the Nina E. Olson & Janet Spragens LITC Award for his work as a student representing low income taxpayers before the IRS.Close