Navigating the IRS Penalty Abatement Procedures for Foreign Information Reporting Noncompliance
Requesting Penalty Abatements for Failure to File Forms 5471, 5472, FATCA, and FBAR
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will provide tax attorneys and accountants with a detailed discussion of best practices for requesting relief of IRS penalties as a result of failing to time file required international information forms such as Forms 5471, 5472, 3520, 3520-8858, 8865, 926, and the FBAR. The panel will discuss the current trends in seeking relief from the imposition of such penalties by the IRS and will provide guidance on drafting abatement requests.
- Summary of most common international tax reporting Forms
- Penalty structure
- What types of behavior result in determinations of willfulness?
- IRS penalty avoidance programs, including the Criminal Investigation division voluntary disclosure program
- Reasonable cause abatement standards
- IRS penalty abatement request process
- Best practices in drafting penalty abatement requests
- What happens when penalty relief fails?
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" relief?
- 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
to be announced.
Cannot Attend September 30?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.