IRS Challenges to Foreign Gifts Received: Failure to File Forms 3520 and 3520-A
Current and Notable Cases, Best Responses to Penalty Assessments
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will address the IRS' current and often overreaching effort to collect penalties related to the filing of Forms 3520, Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts, and 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner. Our panel of international tax experts will review the IRS' penalty regime for inadequate reporting, recent cases regarding the receipt of foreign gifts, and provide examples of the best responses to IRS assessments of penalties relating to reporting foreign gifts received in specific scenarios.
Outline
- IRS challenges to foreign gifts received: introduction
- IRS' attempts to impose taxes on foreign gifts
- Recent notable cases
- Responding to IRS penalty notices
- Best practices and strategies
Benefits
The panel will review these and other critical issues:
- Calculating penalties imposed under IRC Section 6677
- The current state of the IRS' 2018 compliance campaign targeting receipt of foreign gifts
- Current cases against the IRS for assessment of penalties for inadequate or non-filing of Forms 3520 and 3520-A
- Appropriate responses to assessment of penalties for non-filing Forms 3520 and 3520-A
Faculty
Frank Agostino
President
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.
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Matthew L. Roberts
Partner
Meadows, Collier, Reed, Cousins, Crouch & Ungerman
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar... | Read More
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, Income Tax and Business Planning, and Cryptocurrency and Digital Assets. He is Board Certified in Tax Law by the Texas Board of Legal Specialization. Mr. Roberts is a tax litigator and trusted advisor with extensive experience assisting both U.S. and international clients in successfully resolving various federal tax controversies, including civil and criminal liability cases. His expertise covers a broad spectrum of issues, such as tax audits, investigations, litigation, appeals, and collection matters.
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