This program will cover the basic requirements for reporting non-U.S. assets, and then discuss the penalties for failure to file these foreign information returns and other consequences, the procedures for assessment and review, taxpayer defenses, and options for strategies for taxpayers who want to get into compliance.
Course Objectives:
Participants will gain a basic understanding of foreign asset reporting rules and the relevant information returns, penalty exposure for failure for taxpayers’ failure to comply with these rules and possible defenses, the procedures for assessment and review of foreign information return penalties, and strategies for helping clients come into compliance.
Kostelanetz LLP
Partner
[email protected]
(212) 808-8100
Megan L. Brackney concentrates her practice in the areas of civil and criminal tax controversies. Ms. Brackney received her J.D. from the University of Kansas School of Law and her LL.M. in Taxation from New York University. Ms. Brackney teaches Tax Procedure as an adjunct professor at New York University. Ms. Brackney is a former Vice Chair of Committee Operations for the American Bar Association Section of Taxation, a member of the New York State Bar Association Tax Section’s Executive Committee, and a Fellow of the American College of Tax Counsel. Ms. Brackney annually contributes to the two-volume ABA publication, Effectively Representing Your Client Before the IRS, and serves on the editorial board of the The Tax Lawyer. Ms. Brackney has been recognized by New York Super Lawyers” and “Best Lawyers in America,” and Chambers USA has ranked Ms. Brackney as a leader in Tax Controversy.