Victor Jaramillo to Speak on D.C. Bar Webinar on Recent International Information Reporting Cases
Tax controversy professionals - including the current National Taxpayer Advocate - have been bemoaning the complex filing requirements and onerous penalties associated with international information return penalties for years. No longer limited to the notorious FBAR, since before COVID, the IRS has been cracking down on international information reporting forms such as Forms 5471, 5472, 3520, and 3520-A. Appeals has been overrun with cases challenging international information return penalties on the grounds of reasonable cause. This past year, it was the courts' turn to chime in.
This panel will explore the recent string of international information reporting cases (including Fahry, Aroeste, and Bittner) and discuss their implications for the future. Attendees are encouraged to come with their own war stories, tips, tricks and questions!