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LITIGATING FOREIGN ASSET REPORTING TAX PENALTIES: THE CONTROVERSIES CONTINUE

CPE Processing Fee$10.00
Webinar TranscriptionN/A
Presentation Length Hour(s)1.0 hour
CPE Credits 1.0 hour
Subject Area 1.0 - Taxes (Federal Tax Update)
CE Credits 1.0 hour
Course Id# - HURS9-U-00477-19-S
Course LevelBasic
Instructional MethodQAS Self-Study
PrerequisitesNone
Advance PreparationNone
Recorded DateJune 20, 2019
Date OfferedAugust 7, 2019
Expiration DateAugust 7, 2020
Course Description

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.

Learning Objectives

  • Identify issues and controversies surrounding litigation of foreign asset reporting and the related tax penalties.

7
Handout Materials
Presentation Slides
Review Questions
Review Questions
QUESTION 1: 0:21:00 minutes
QUESTION 2: 0:37:00 minutes
QUESTION 3: 0:51:00 minutes
Frequently Asked Questions
  • CPAacademy self-study courses are online.
  • The self-study format allows you to a) access the material online 24/7 and b) study at your own pace.
  • Per NASBA guidelines, you have one year from date of purchase to complete each program.
  • Complete your final exam at any time and get graded instantly. You can retake the exam at no additional charge (unlimited attempts).
  • Print your own certificate of completion on the spot upon passing the exam.
  • Grading policies: a) courses have a minimum passing score 70% b) test takers will not be provided feedback on failed exams.
  • Upon achieving a passing score, test takers will be notified of the correct answers to the questions missed.

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Lindsey Stellwagen

IRS
Special Counsel (International)

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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.

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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.

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Hochmansalkintoscherperez

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.

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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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About Our Presenter

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For nearly 85 years, the NYU School of Professional Studies has been a deeply respected institution of higher education grounded in applied learning. It has served as a source of empowerment for individuals from NYC, across the country, and worldwide who aspire to become the next generation of leaders and innovators of industry.

Throughout its rich history, NYUSPS has met the needs of the students and the professional communities it serves. From its early years of training returning World War II veterans to fulfill the nation’s urgent need for skilled technical workers, it has evolved into a professional education powerhouse that offers 19 graduate degrees, 13 bachelor’s degrees, four associate’s degrees, and a plethora of non-degree courses