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Foreign Information Return Penalties After Farhy: Impact of DC Circuit Court Decision

A live 110-minute CPE webinar with interactive Q&A

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Thursday, July 18, 2024

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, June 21, 2024

or call 1-800-926-7926

This webinar will examine the impact of Farhy v. Commissioner on foreign information return reporting penalties and detail the actions international tax practitioners need to take in light of this case, including the recent D.C. Circuit Court ruling. Our panel of prestigious tax attorneys from the firm representing Alon Farhy will explain how this case impacts foreign information return reporting, including penalties assessed in the past and pro-active steps practitioners should take for their international clients.

Description

In Farhy v. Commissioner 160 T.C. No. 6 (T.C. Apr. 3, 2023), the Tax Court ruled that the IRS did not have the authority to assess and collect penalties under IRC Section 6038(b) for failure to file Forms 5471. On appeal, the D.C. Circuit Court overturned the Tax Court decision. This case has ramifications for other forms, including Forms 5472, 8858, 8938, 926, and perhaps even Form 3520.

International tax advisers need to know how the IRS will likely respond to this decision, how this decision impacts taxpayers in other circuits, and the impact of a potential appeal to the U.S. Supreme Court.

Listen as our panel from Hochman Salkin Toscher & Perez, P.C., the firm representing Farhy, reviews Farhy v. Commissioner and offers advice pertaining to claims for wrongful assessment of foreign reporting penalties.

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Outline

  1. Foreign return penalties: introduction
  2. Farhy v. Commissioner
  3. Impact on other foreign information reporting returns
  4. Penalty abatement
  5. Refund claims
  6. 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

Horwitz, Robert
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

Robbins, Jr., Edward M.
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

Stein, Michel
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

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