Foreign Late Filing Notices: Effective Responses for Penalty Abatement
Reasonable Cause, First Time Abatement, Reliance on a Professional, Exercising Ordinary Care and Prudence
Recording of a 110-minute CPE webinar with Q&A
This webinar will examine the current state of IRS responses to international taxpayers' requests for penalty relief for late filing of foreign information returns. Our astute panel of international tax experts will review what constitutes reasonable cause, when first-time abatement applies, and will offer tips for working with the IRS to eliminate or lessen the penalties frequently and automatically assessed to international taxpayers.
Outline
- Late filing notices: introduction
- Applicable forms
- Penalties assessed
- Related regulations
- Defenses
- Reasonable cause
- First-time penalty abatement
- Other responses
- Appeals
- Court
- Relevant cases
- Delinquent International Information Return Submission Procedures
- Best practices
Benefits
The panel will cover these and other critical issues:
- When is reliance on a professional a reasonable defense to foreign late filing penalties?
- When is first-time penalty abatement relief available for late-filed foreign information returns?
- How does a taxpayer meet the ordinary business care and prudence standard?
- How should tax practitioners respond when the IRS denies a request for penalty relief?
Faculty
Frank Agostino
President
Agostino & Associates
Mr. Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice,... | Read More
Mr. Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. Mr. Agostino also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, he taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. Mr. Agostino also served as the co-director of the Rutgers Federal Tax Law Clinic.
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Guy Glaser
Attorney
Brager Tax Law
Mr. Glaser has over 30 years of tax experience with the IRS. He spent the first twenty years as a Senior Trial Attorney... | Read More
Mr. Glaser has over 30 years of tax experience with the IRS. He spent the first twenty years as a Senior Trial Attorney for the Service’s Office of Chief Counsel’s Small Business and Self-Employed (SBSE) Division. For the next 10 years, he served as the Laguna Niguel Associate Area Counsel for the IRS Office of Chief Counsel’s Large Business and International (LB&I) Division. He also worked a 6-month stint as a Special Assistant United States Attorney for the Office of the United States Attorney, Central District of California, Tax Division in Los Angeles. As a Senior Trial Attorney for the IRS Office of Chief Counsel’s Small Business and Self-Employed Division, Mr. Glaser was responsible for providing legal advice to the IRS on tax audits and collection matters. He also assisted in implementing the IRS’s Offshore Compliance Initiative and the Offshore Credit Card Program. He served as one of the initial eleven nationwide IRS Office of Chief Counsel FBAR Coordinators
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Matthew L. Roberts, J.D., LL.M.
Partner
Gray Reed
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients... | Read More
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Mr. Roberts brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships and corporations.
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