FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, Defense Strategies, Recent Cases, Penalties
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax counsel and advisers a critical analysis of FBAR investigations, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, recent IRS guidance and relief for certain taxpayers, and new cases with issues of first impression as such relate to FBAR compliance.
Outline
- Navigating the FBAR investigation and assessment process
- Critical compliance issues and resolution options
- Penalties and designing FBAR defense strategy
- Litigation; recent cases and IRS enforcement actions
Benefits
The panel will review these and other key issues:
- What are the international tax compliance issues and pitfalls to avoid?
- What foreign reporting forms are subject to foreign tax reporting penalties?
- How can you minimize the risk of audits?
- What are the penalty structures for non-willful and willful failure to file?
- What is the IRS penalty abatement decision-tree model, and how does it apply to requests to abate foreign tax penalties?
- What are the standards for "reasonable cause" abatement?
- What are the critical challenges of FBAR controversies, administrative appeals, and the district court and the court of federal claims litigation?
Faculty
Yevgeny Antonov
Director
PKF O’Connor Davies
Mr. Antonov has eight years of experience in federal, state and international income tax. He has worked with... | Read More
Mr. Antonov has eight years of experience in federal, state and international income tax. He has worked with multinational businesses and high net-worth individuals, including U.S. subsidiaries of foreign corporations and partnerships. Mr. Antonov provides support on U.S. entity formation and dissolution issues, state and local tax, tax treaty and expat tax issues. He has represented corporate and individual clients before the Internal Revenue Service and state tax departments in connection with tax examinations, and tax controversies.
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Thomas Kinder
Director
PKF O’Connor Davies
Mr. Kinder has more than seven years of experience in public accounting. His expertise is in international tax... | Read More
Mr. Kinder has more than seven years of experience in public accounting. His expertise is in international tax consulting for both corporate and individual taxpayers. Mr. Kinder also has experience in the international sector focusing on cross-border transactions, internal reorganizations and M&A transactions. He contributes articles to the organization’s Thought Leadership series, as well as to outside professional publications.
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Christopher Migliaccio
Partner
PKF O'Connor Davies
Mr. Migliaccio is a Partner in the international tax practice. Prior to joining PKF O’Connor Davies, he worked at... | Read More
Mr. Migliaccio is a Partner in the international tax practice. Prior to joining PKF O’Connor Davies, he worked at two “Big 4” accounting firms in their international tax practices. Mr. Migliaccio has more than 10 years of experience providing consultation on international tax matters, including cross-border transactions, business restructurings and complex compliance issues for multinational corporations, partnerships, private equity funds and high-net-worth individuals. In addition, he regularly leads due diligence and structuring for M&A transactions. As one of the Firm’s most prolific thought leaders, Mr. Migliaccio has written extensively on a wide range of tax topics. He is a co-author of treatise-length discussions on the Base Erosion and Anti-Abuse Tax (BEAT), Passive Foreign Investment Companies (PFICs) and Inversions. Mr. Migliaccio has authored articles for publications such as Law360 and Checkpoint News and has been quoted in Newsday and Bloomberg News. He is also a frequent speaker at industry and tax-related conferences.
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Cannot Attend July 10?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.