ROBERT HORWITZ to speak at the upcoming ABA Annual May Meeting entitled “Litigating International Penalties in Collection” Grand Hyatt, Washington D.C.
We are pleased to announce that Robert Horwitz will be presenting at the upcoming ABA 2019 May Tax Meeting, Friday, May 10, 2019 from 4:45 p.m. to 5:45 p.m. (EST).
Many penalties resulting from failing to report foreign income and assets are assessable (i.e., the deficiency procedures do not apply). This panel will discuss the procedures that apply after the IRS Examination Division assesses or proposes an assessment of a penalty for failing to report foreign income or assets. The panelists will explain the options available to contest and/or compromise the international penalties under Title 26, including accelerated appeals, collection due process hearings, collection alternatives, and Tax Court litigation. Among the penalties to be covered are international information return penalties, accuracy-related penalties due to undisclosed foreign financial asset understatements, and the fraud penalty.
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