Overcoming FBAR Penalties: Best Practices and Practical Tips
Over the years, the Internal Revenue Service (IRS) has enforced drastic penalties for inaccurate, late, and non-filing of Foreign Bank Account Report (FBAR). Fines can range from $10,000 for non-willful violations to over 100% of the unaccounted foreign accounts’ aggregated amount for multiple willful violations.
With such high fines and penalties or even a criminal investigation, where an individual’s reputation is at stake, it is imperative for businesses and individuals to understand common triggers and pitfalls to be able to mitigate risks of exposure. They should keep themselves abreast of the best practices and practical tips than can help them overcome FBAR penalties.
Listen as a panel of distinguished tax litigators and experts organized by The Knowledge Group provide the audience with an overview of the FBAR and its penalties. Speakers, among other things, will also offer helpful insights on compliance strategies and tips on how to overcome FBAR Penalties.
In a LIVE Webcast, the speakers will discuss:
- FBAR Penalties: Overview
- Standards, Procedures and Defenses
- Common Risks and Pitfalls
- Compliance Strategies
- What Lies Ahead in 2019 and Beyond
Hochman Salkin Toscher Perez, PC
- The difference between the FBAR willful penalty and the non-willful penalty
- Settling the FBAR penalty prior to litigation
- Statute of limitations for suits by Government to collect and by taxpayers for refund of FBAR penalty
- Jurisdiction and venue for FBAR cases
- Right to Jury Trial in FBAR cases
- Defenses to FBAR liability
- What if willful for purposes of the FBAR penalty
- Status of litigation concerning the validity of regulation limiting the maximum willful penalty to $100,000
Robert Horwitz is a principal with Hochman, Salkin, Rettig, Toscher & Perez, PC, in Beverly Hills, CA, where he specializes in the representation of clients in civil and criminal tax cases. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and as Chair of the Taxation Section for 2015-2016. Before entering private practice, Mr. Horwitz was a trial attorney in the U.S. Department of Justice Tax Division and the U.S. Attorney’s Office in Los Angeles.
Mr. Horwitz has been a speaker on tax matters and FBAR penalties at the Annual Meeting of the Taxation Section of the California Lawyers Association, the ABA Section of Taxation Mid-Year Meeting, the UCLA Tax Controversy Institute, the Procopio International Tax Institute and the California State Bar Annual Meeting. He has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the CCH Journal of Tax Practice & Procedure, the Federal Lawyer (the publication of the Federal Bar Association), the California Tax Lawyer and the California Journal of Tax Litigation.
Mr. Horwitz is a member of the bars of California and Illinois. He is admitted to practice before the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012 and 2014-2019. He is a member of the American College of Tax Counsel and of the Planning Committee of the UCLA Tax Controversy Institute.
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About Hochman Salkin Toscher Perez, PC
Hochman Salkin Toshcer Perez, P.C., specializes in representing clients in civil and criminal tax cases both administratively before the Internal Revenue Service and state taxing agencies and in court. The firm is internationally recognized for excellence, integrity and the ability to achieve the best possible results for our clients throughout the world. Our experienced tax lawyers have outstanding tax-related credentials and are routinely recognized as leaders in handling all aspects of sophisticated tax controversies and criminal tax matters.