Foreign Late Filing Notices: Effective Responses for Penalty Abatement
Reasonable Cause, First Time Abatement, Reliance on a Professional, Exercising Ordinary Care and Prudence
Recording of a 110-minute CPE webinar with Q&A
This webinar will examine the current state of IRS' responses to international taxpayers' requests for penalty relief for late filing of foreign information returns. Our astute panel of international tax experts will review what constitutes reasonable cause, when first-time abatement applies, and offer tips for working with the IRS to eliminate or lessen the penalties frequently and automatically assessed to international taxpayers.
- Late filing notices: introduction
- Applicable forms
- Penalties assessed
- Related regulations
- Reasonable cause
- First-time penalty abatement
- Other responses
- Relevant cases
- Delinquent International Information Return Submission Procedures
- Best practices
The panel will cover these and other critical issues:
- When reliance on a professional is a reasonable defense to foreign late filing penalties
- When is first-time penalty abatement relief available for late-filed foreign information returns?
- How does a taxpayer meet the ordinary business care and prudence standard?
- How should tax practitioners respond when the IRS denies a request for penalty relief?
Agostino & Associates
Mr. Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice,... | Read More
Mr. Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. Mr. Agostino also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, he taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. Mr. Agostino also served as the co-director of the Rutgers Federal Tax Law Clinic.Close
Kundra & Associates
Ms. Kundra is a tax law adviser, litigator, and tax controversy attorney who operate practices in Maryland and... | Read More
Ms. Kundra is a tax law adviser, litigator, and tax controversy attorney who operate practices in Maryland and Washington, D.C. with clients local, nationwide, and residing all over the world. Her practice focuses on tax controversy and international tax compliance, among others. Her practice serves entrepreneurs, businesses and individuals with legal, tax and financial counseling.Close
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