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Where In The World…? Recent Updates In International Information Return Caselaw And Practice

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Where In The World…? Recent Updates In International Information Return Caselaw And Practice

January 24 @ 12:30 pm - 1:30 pm EST

Heather Fincher will participate in a panel titled “Where in the World…? Recent Updates in International Information Return Caselaw and Practice” hosted by the D.C. Bar on January 24, 2024. The conference will be held virtually.

Event Description: 

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!

Pre-registration for this program is required. As always, please feel free to share this invitation with colleagues. D.C. Bar membership is not required to attend. Non-members will need to create a profile to register and access the content.

Sponsored by: Tax Audits and Litigation Committee of the D.C. Bar Taxation Community


Heather Fincher, Associate, Kostelanetz LLP

Pedro Corona de la Fuente, Partner, Procopio, Cory, Hargreaves & Savitch LLP

Victor Jaramillo, Member, Caplin & Drysdale, Chartered

Visit here for registration and event details.