It’s been more than a decade since the wall of Swiss bank secrecy fell revealing the extent to which US taxpayers had unreported foreign assets. In the intervening years, the IRS has continued its focus on finding and penalizing those assets. The law and procedures regarding FBAR, 5471, 8938, and 3520 penalties have been developing rapidly as taxpayers contest the assessment of liabilities that can be unexpectedly large. This panel discusses the latest developments relating to foreign asset reporting penalties, as well as practical tips for representing taxpayers contesting the imposition of such penalties.
Identify issues and controversies surrounding litigation of foreign asset reporting and the related tax penalties.
Lindsey Stellwagen serves as Special Counsel International (SBSE) in the IRS Office of Chief Counsel, Washington, D.C. field office. She provides international litigation support and advice to Withholding & International Individual Compliance Practice Area (LB&I) and Special Enforcement Program (SBSE). Her work covers diverse areas such as offshore banking & structures, foreign government employees, foreign information gathering, treaty analysis, informant cases, ex-pats, foreign athletes & entertainers, and estate work.
Phillip J. Colasanto is an attorney at Agostino & Associates, P.C. where he focuses on civil and criminal tax controversies. Mr. Colasanto is a frequent presenter for the American Bar Association and has published articles for: Tax Notes, Bloomberg BNA, American Law Institute, and the Journal of Tax Practice and Procedure. Mr. Colasanto was recently named one of the Nolan Fellows for the American Bar Association, which is awarded to young lawyers who are actively involved in the Tax Section and have shown leadership qualities.
Steven Toscher is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization.
Jeffrey A. Neiman is an accomplished trial attorney who focuses on white-collar defense, tax controversies, securities regulatory matters, and general litigation. Upon graduating with honors from law school at the University of Florida, Mr. Neiman was hired as a federal prosecutor through the prestigious United States Department of Justice Attorney General’s Honors Program. For nearly nine years, Mr. Neiman worked as an Assistant United States Attorney and Trial Attorney for the Department of Justice in South Florida and in Washington, D.C.
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