FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, FBAR Defense Strategies, Recent Cases, Penalties
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers a critical analysis of FBAR examination, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, IRS guidance and relief for certain taxpayers, and new cases with issues of first impression relating to FBAR compliance.
- Critical compliance issues and resolution options
- Navigating the FBAR examination and assessment process and administrative appeals
- Penalties and FBAR defense strategy
- Litigation; recent cases and IRS enforcement actions
The panel will review these and other key issues:
- What are the standards for "reasonable cause" abatement?
- What are the critical challenges of FBAR controversies, administrative appeals, the district court, and the court of federal claims litigation?
- Why does the APA provide possible grounds for defending against FBAR penalty assessments that are not available to taxpayers challenging other IRS foreign-related penalties?
James (Jim) Dawson
Holland & Knight
Mr. Dawson is a highly experienced tax litigator and business advisor with extensive knowledge resolving Internal... | Read More
Mr. Dawson is a highly experienced tax litigator and business advisor with extensive knowledge resolving Internal Revenue Service (IRS) controversies in audit, appeals and litigation. His practice focuses on representing corporations and individual taxpayers in tax controversy and tax litigation matters.Close
Zhanna A. Ziering
Caplin & Drysdale
Ms. Ziering offers guidance to individual and corporate clients who require sophisticated tax advice concerning their... | Read More
Ms. Ziering offers guidance to individual and corporate clients who require sophisticated tax advice concerning their domestic tax issues, offshore assets, and U.S. reporting requirements. Clients rely on her deep knowledge of tax controversies and tax litigation, as well as her experience with related civil, criminal, and regulatory proceedings. She represents both individuals and corporations before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators.Close