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.
IRS
Special Counsel (International)
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.
Withers Bergman LLP
Senior Associate
phillip.colasanto@withersworldwide.com
Phil is a senior associate at Withers Bergmen LLP (Withers Worldwide). Phil’s practice is focused on domestic and international tax controversy. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts. He has represented clients from audit through trial and, if necessary, at the appellate level.
Phil has spoken on various tax topics and at various forums, including the American Bar Association, New York County Lawyers' Association, IRS Nationwide Virtual Tax Forum, CPA Academy, and NYU Tax Controversy Forum. He has also published several tax-related articles, which have been published by Tax Notes, Bloomberg BNA, Journal of Tax Practice and Procedure, EA Journal, and The Practical Lawyer. In addition to his publication and speaking engagement, he is heavily involved with the American Bar Association, where he is the incoming Chair of the Tax Collections Bankruptcy and Workouts Committee.
Hochman, Salkin, Toscher & Perez, P.C.
Principal, PC
toscher@taxlitigator.com
(310) 281-3220
Steven Toscher is a principal of Hochman, Salkin, 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.
Marcus Neiman Rashbaum & Pineiro
Partner
jneiman@mnrlawfirm.com
(305) 400-4260
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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