Foreign Information Return Penalties After Farhy: Case Review and Updates, Penalty Abatements, Refund Claims
Recording of a 110-minute CPE webinar with Q&A
This webinar will review the decision in Farhy v. Commissioner and detail the actions international tax practitioners need to take in light of this case. Our panel of prestigious tax attorneys, from the firm that represented Farhy, will explain how this decision impacts foreign information return reporting, including penalties assessed in the past, and steps practitioners should take to preserve the benefits of this taxpayer-favorable ruling for their international clients.
Outline
- Foreign return penalties: introduction
- Farhy v. Commissioner
- Impact on other foreign information reporting returns
- Penalty abatement
- Refund claims
- Best practices
Benefits
The panel will cover these and other critical issues:
- How does the Farhy decision affect current and past late-filed foreign information returns?
- How many past years could possibly be eligible for refunds?
- What is the current status of Fahry v. Commissioner?
- Which clients are eligible for refunds or abatement of previously assessed penalties?
- What steps should tax advisers take to ensure clients receive refunds for previously filed returns?
- How can practitioners ensure clients are not assessed penalties for current and late filed Forms 5471?
Faculty
Robert Horwitz
Principal
Hochman Salkin Toscher Perez
Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil... | Read More
Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. Mr. Horwitzwas previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section. Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board. He has been a speaker on tax matters at the UCLA Tax Controversy Institute, the Annual Meeting of the Taxation Section of the California Bar and the California State Bar Annual Meeting. Mr. Horwitz has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the Federal Lawyer (the publication of the Federal Bar Association), and the California Tax Lawyer. His monograph in “Responsible Persons and Fiduciary Liability” was published in the Proceedings of the New York University 75th Institute on Federal Taxation. Mr. Horwitz was an invited delegate to the 2015 U.S. Tax Court Judicial Conference. He is a member of the Planning Committee of the UCLA Tax Controversy Institute. Mr. Horwitz is a member of the bar in California and in Illinois. He is admitted to practice in the United States District Courts for the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018.
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Edward M. Robbins, Jr.
Principal
Hochman Salkin Toscher Perez
Mr. Robbins has considerable experience handling sensitive issue civil examinations and administrative appeals, civil... | Read More
Mr. Robbins has considerable experience handling sensitive issue civil examinations and administrative appeals, civil trials and appeals defending complex criminal tax investigations, civil trials and appeals, and defending criminal tax prosecutions (jury and non-jury). He has successfully handled literally hundreds of matters involving previously undeclared interests in foreign financial accounts and assets.
Representation currently includes Federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy administrative matters before the Internal Revenue Service, the California Franchise Tax Board, the California State Board of Equalization, California Employment Development Department and various state taxing authorities of individuals, business enterprises, partnerships, limited liability companies, and corporations. Representation also includes individuals and organizations involved as targets, subjects, or witnesses in Federal and California criminal investigations and related grand jury and pre-trial proceedings, trials and appeals. In the world of civil tax and criminal tax investigations, Mr. Robbins has truly touched every conceivable issue during his lengthy and successful career.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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