Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and Appeals
Program Description:
The IRS employs strict standards for determining whether a taxpayer qualifies for an abatement of penalties for failure to file required foreign information returns and FBARs.
The U.S. Treasury Inspector General for Tax Administration (TIGTA) issued a report in recent years showing that IRS controls over penalties were deficient, leading to incorrect abatement in a large percentage of tested cases. As a result, the IRS has promised increased scrutiny over foreign penalty abatement requests.
Regardless, IRS audits have not become easier. Once chosen, a taxpayer can expect to face a probing investigation, potentially leading to stiff penalties. Critical to navigating the FBAR and foreign information reporting forms appeals process is an understanding of what the legal standards are, what level of penalty is being applied, what arguments (legal and otherwise) can be made, as well as determining how the evidence can best be assembled. Counsel and advisers must be prepared to present comprehensive and cohesive case for taxpayers seeking to appeal their FBAR and other penalties.
Anthony E. Parent, Founding Partner at Parent & Parent; Dennis N. Brager, Esq. at Brager Tax Law Group and Robert Hanson, Esq., International Tax Attorney at Parent & Parent, 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 major foreign information reporting forms and their associated penalties, foreign information and FBAR abatement requests, and will offer useful tools for compiling and submitting the appeal correspondence and documentation.
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
Or call 1-800-926-7926 ext. 10
Ask for Appealing IRS Penalty Abatement Denials on 11/1/2017
