Navigating the IRS Penalty Abatement Procedures for Foreign Information Reporting Noncompliance
Requesting Penalty Abatements for Failure to File Forms 5471, 5472, FATCA and FBAR
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel with a detailed discussion of best practices for requesting abatements of IRS penalties due to failure to properly file required international information forms such as the FBAR, Form 8938, and Forms 5471 and 5472. The panel will discuss the current trends in IRS abatement and will provide guidance on drafting abatement requests.
- OVDP and penalty avoidance programs
- What happens when penalty avoidance fails?
- Penalty structures
- Reasonable cause abatement standards
- Best practices in drafting penalty abatement requests
- IRS penalty abatement request process
The panel will review these and other key issues:
- What foreign reporting forms are subject to foreign tax reporting penalties?
- What are the penalty structures for non-willful and willful failure to file?
- What are the standards for “reasonable cause” abatement?
- What is the IRS penalty abatement decision tree model and how does it apply to requests to abate foreign tax penalties?
- What standards are used by the courts, and the IRS to determine willfulness?
- How can the IRS Streamlined Procedures be used to mitigate various penalties?
Dennis N. Brager, Esq.
Brager Tax Law Group
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and... | Read More
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and tax controversy matters. Before founding the Brager Tax Law Group, a Los Angeles-based tax litigation and tax controversy law firm, he was a senior trial attorney for the Internal Revenue Service’s Office of Chief Counsel. Since 2008 he has represented several hundred clients with offshore accounts. He also represents clients on a variety of issues, including criminal and civil tax fraud, tax audit and appeals, payroll and sales tax problems, tax preparer penalties, innocent spouse defenses, offers in compromise, installment payment agreements, Office of Professional Responsibility (“OPR”) defenses and more.Close
Joel N. Crouch
Meadows Collier Reed Cousins Crouch & Ungerman
Mr. Crouch specializes in civil and criminal tax controversies involving sophisticated and... | Read More
Mr. Crouch specializes in civil and criminal tax controversies involving sophisticated and complex legal and tax issues, both domestic and international. He has extensive experience in resolving tax matters at all stages of a tax dispute including IRS examinations, administrative appeals, and litigation in the U.S. Tax Court, the U.S. Court of Federal Claims and U.S. District Courts, and before the United States Supreme Court. He is a frequent speaker on both substantive and procedural tax issues for both legal and accounting professionals.Close