by David J. Warner | Apr 4, 2023 | FBAR, Internal Revenue Service, Offshore Income, U.S. Tax Court
On April 3, 2023, the U.S. Tax Court issued its opinion in Farhy v. Commissioner, 160 T.C. No. 6 (2023). This case deals a major blow to the Internal Revenue Service (IRS) and its efforts to collect penalties related to certain international information returns. Did...
by Michele Weiss | Apr 4, 2023 | FBAR, Internal Revenue Service, Offshore Income
Michele Weiss, Principal at Holtz, Slavett & Drabkin, will participate in a Beverly Hills Bar Association panel exploring how to navigate the new landscape for Foreign Bank Account Report (FBAR) penalties in light of the U.S. Supreme Court decision in Bittner v....
by David J. Warner | Nov 15, 2022 | Audit, Internal Revenue Service, Offshore Income
Holtz, Slavett & Drabkin tax attorneys, principals, and shareholders Igor S. Drabkin and David J. Warner will be co-presenting a Federal Bar Association webinar entitled “Types of IRS Tax Penalties and the Penalty Abatement Process: What attorneys should know” on...
by David J. Warner | Oct 5, 2022 | Audit, Firm News, Internal Revenue Service, Offshore Income
Holtz, Slavett & Drabkin tax attorneys, principals, and shareholders Igor S. Drabkin and David J. Warner will be co-presenting a Strafford webinar entitled “Complex IRS Penalty Abatement Procedures for Failure-to-File, Failure-to-Pay” on Thursday, November 3,...
by David J. Warner | Aug 5, 2022 | Firm News, Internal Revenue Service, Offshore Income
Holtz, Slavett & Drabkin tax attorney, principal, and shareholder David J. Warner will be co-presenting a Strafford webinar entitled “Taxation of Foreign Branches Under Current Tax Law: Qualified Business Units, Foreign Tax Credits, Anti-Hybrid Rules” on...
by David J. Warner | Jun 22, 2022 | FBAR, Internal Revenue Service, Offshore Income
On June 21, 2022, the U.S. Supreme Court decided to review (that is, granted certiorari) in the case of Bittner v. United States. This case centers around the report of foreign bank and financial accounts (FBAR) and penalties for not timely filing the FBAR form. The...