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
- 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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Matthew L. Roberts
Partner
Meadows, Collier, Reed, Cousins, Crouch & Ungerman
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar... | Read More
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, Income Tax and Business Planning, and Cryptocurrency and Digital Assets. He is Board Certified in Tax Law by the Texas Board of Legal Specialization. Mr. Roberts is a tax litigator and trusted advisor with extensive experience assisting both U.S. and international clients in successfully resolving various federal tax controversies, including civil and criminal liability cases. His expertise covers a broad spectrum of issues, such as tax audits, investigations, litigation, appeals, and collection matters.
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