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 premium CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax attorneys and accountants 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.
- IRS penalty avoidance programs including the new voluntary disclosure program.
- What happens when penalty avoidance fails?
- Penalty structures
- Reasonable cause abatement standards
- What types of behavior result in determinations of willfulness?
- IRS penalty abatement request process
- Best practices in drafting penalty abatement requests
The panel will review these and other key issues:
- What foreign reporting forms are subject to penalties, and how are the penalties calculated, including current litigation on this issue?
- What are the penalty structures for non-willful and willful failure to file? What standards are used by the IRS and the courts?
- What are the standards for "reasonable cause" abatement?
- How can the IRS' streamlined procedures be used to mitigate various penalties?
Dennis N. Brager, Esq.
Certified Tax Specialist
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
Ms. Obeid is the founder of MFO LAW, P.C. She represents individual and corporate clients in civil and criminal matters... | Read More
Ms. Obeid is the founder of MFO LAW, P.C. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the tax division of the Department of Justice, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General as well as other government agencies.Close