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. The panel will provide an overview of the major foreign information reporting forms and their associated penalties, foreign information and FBAR abatement requests, and will offer useful tools for compiling and submitting the appeal correspondence and documentation.
- Not just the FBAR—review of foreign reporting form
- The reasonable cause standard for foreign reporting penalties
- Handling OVDP opt-outs, streamlined submissions, and FBAR audits
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
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