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
Austin C. Carlson, CPA
Partner, CPA
Gray Reed & McGraw
Mr. Carlson brings unique skills and perspectives to every area of his practice, which includes complex tax planning... | Read More
Mr. Carlson brings unique skills and perspectives to every area of his practice, which includes complex tax planning for domestic and international transactions, real estate fund and joint venture tax and corporate representation, and tax counsel on mergers and acquisitions. He helps companies (domestic and international) and individuals structure corporations, LLCs, partnerships and nonprofit entities, achieve their transactional tax and corporate planning goals, and successfully resolve tax controversies with the IRS and state taxing authorities. Mr. Carlson also has substantial experience with all types of foreign account and income disclosure issues including the Streamlined Filing Compliance Procedures and Delinquent International Information Return Submission Procedures.
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Patrick J. McCormick, J.D., LL.M.
Partner
Rimon Law
Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has... | Read More
Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.
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Cannot Attend February 28?
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.