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 from IRS penalties as a result of failing to timely 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 guide advisers on drafting abatement requests.
Outline
- 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?
Benefits
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?
Faculty
Samuel Landis
Senior Partner
Segal, Cohen & Landis
Mr. Landis has been a practicing tax attorney for over 30 years. In addition to his law degree, he possesses a... | Read More
Mr. Landis has been a practicing tax attorney for over 30 years. In addition to his law degree, he possesses a Master’s Degree in Taxation (LL.M.) from Boston University. Since 1997, Mr. Landis has been the founder and managing partner of the tax law firm Segal, Cohen & Landis, P.C. (SCL). He has personally handled thousands of tax cases himself, many of which have been the largest and most complex cases in their respective industries including sports, entertainment and gaming. Because of the high profile nature of many of Samuel’s cases, they have been frequently reported in various prestigious national publications and news outlets. Additionally, Mr. Landis is recognized and has been called upon as an expert witness in various court cases involving tax issues.
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Patrick J. McCormick, J.D., LL.M.
Founder/Managing Partner
McCormick Tax
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.
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Cannot Attend December 2?
Early Discount (through 11/08/24)
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.