Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign information reporting forms, their associated penalties, and FBAR abatement requests. The panel will offer useful tools for compiling and submitting the appeal correspondence and documentation.
Outline
- Not just the FBAR: a review of the foreign reporting forms
- The administrative remedy paths: proactive and reactive
- The review standards: willfulness and reasonable cause
Benefits
The panel will review these and other key issues:
- Recognize approaches to resolve international controversies
- Identify the types of lesser-known foreign assets transactions that trigger significant penalty risks
- Determine legal and practical issues that can erupt in these cases and approaches to mitigate those risks
- Discuss the relevant law applied during audit and appeal
Faculty
Jonathan Kalinski
Principal
Hochman Salkin Toscher Perez
Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including... | Read More
Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters. Prior to joining the firm, he served as a trial attorney with the IRS Office of Chief Counsel litigating Tax Court cases and advising revenue agents and revenue officers on a variety of complex tax matters.
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Edward M. Robbins, Jr.
Principal
Hochman Salkin Toscher Perez
Mr. Robbins has considerable experience handling sensitive issue civil examinations and administrative appeals, civil... | Read More
Mr. Robbins has considerable experience handling sensitive issue civil examinations and administrative appeals, civil trials and appeals defending complex criminal tax investigations, civil trials and appeals, and defending criminal tax prosecutions (jury and non-jury). He has successfully handled literally hundreds of matters involving previously undeclared interests in foreign financial accounts and assets.
Representation currently includes Federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy administrative matters before the Internal Revenue Service, the California Franchise Tax Board, the California State Board of Equalization, California Employment Development Department and various state taxing authorities of individuals, business enterprises, partnerships, limited liability companies, and corporations. Representation also includes individuals and organizations involved as targets, subjects, or witnesses in Federal and California criminal investigations and related grand jury and pre-trial proceedings, trials and appeals. In the world of civil tax and criminal tax investigations, Mr. Robbins has truly touched every conceivable issue during his lengthy and successful career.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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