FBAR 2023 Update: Filing Requirements, Recent Cases, Deadlines, Extension, Penalty Resolution, and Waiver Provisions
Who Must File, What Must Be Reported, Willful vs. Non-Willful Failures
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to completing the FBAR filing requirements. The panel will offer detailed instructions on completing and filing an FBAR, discuss recent IRS penalty enforcement actions for non-filing of foreign bank accounts, review recent cases, and describe extension provisions for the current filing year.
Outline
- What triggers FBAR filing requirements
- Entity ownership
- $10,000 threshold
- When are a company's officers personally responsible?
- Information to report on the FBAR vs. Form 8938
- Ownership accounts, accounts with signature authority, combined report accounts
- Form 8938 and associated IRS forms for foreign ownership/transactions
- Update on enforcement and new developments
- FBAR and Form 8938 penalties
- Willfulness standard and the non-willful certification
- Avenues and procedures
- Audits and examination
- Civil vs. criminal sanctions
Benefits
The panel will review these and other key issues:
- When can corporate officers' stake in foreign accounts trigger reporting responsibilities?
- What is the latest in the IRS and FinCEN enforcement activity?
- What are the options for companies required to file an FBAR and have not?
- How do Form 8938 filing requirements intersect with FBAR?
Faculty
Igor S. Drabkin
Tax Attorney & Principal
Holtz, Slavett & Drabkin
Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively... | Read More
Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively and in court. Previously in his career, he was a senior IRS trial attorney and a special assistant U.S. attorney on bankruptcy cases involving tax matters.
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Gary Slavett
Principal and Founder
Holtz, Slavett & Drabkin
Mr. Slavett is a principal and founder of Holtz, Slavett & Drabkin, A Professional Law Corporation. He has been a... | Read More
Mr. Slavett is a principal and founder of Holtz, Slavett & Drabkin, A Professional Law Corporation. He has been a California licensed attorney since 1996 and has over 25 years of experience in the practice of tax law. Mr. Slavett's practice focuses on all tax controversy matters including issues related to Foreign Bank Accounts & FBAR penalties, tax litigation, tax audit representation, tax administrative appeals, and criminal tax matters. He also handles matters related to the Bank Secrecy Act and Administrative and Civil Forfeitures. Mr. Slavett frequently represents his clients before the United States Tax Court, U.S. District Court, Internal Revenue Service (IRS), United States Attorneys Office, California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA), California State Board of Equalization (BOE), California Employment Development Department (EDD), California Office of Tax Appeals (OTA) and California Unemployment Insurance Appeals Board (CUIAB).
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