Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and Appeals

Recording of a 90-minute CLE/CPE webinar with Q&A

Conducted on Wednesday, November 1, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

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.


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

The U.S. Treasury Inspector General for Tax Administration (TIGTA) 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.

Regardless, IRS audits have not become easier. 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 an understanding of what the legal standards are, what level of penalty is being applied, what arguments (legal and otherwise) can be made, as well as determining how the evidence can best be assembled. Counsel and advisers must be prepared to present 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 OVDP and penalty abatement denials. Attendees will receive an insider’s look at how complicated international controversies were successfully resolved by leading practitioners in the field.



  1. Not just the FBAR—review of foreign reporting form
  2. The reasonable cause standard for foreign reporting penalties
  3. 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


Parent, Anthony
Anthony E. Parent

Founding Partner
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

Brager, Dennis N.
Dennis N. Brager, Esq.

Certified Tax Specialist
Brager Tax Law Group

Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and...  |  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

Other Formats
— Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video



CPE Not Available