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Tag: Megan L. Brackney

The IRS’s Assessment Of Penalties On Substitute Forms 3520-A

By Megan L. Brackney Tax Notes International, Volume 102 Issue 3 Tax Notes Federal, Volume 171 Issue 3 April 19, 2021 In recent months, we have seen several clients being heavily penalized for purportedly late filing Form 3520-A, “Annual Information Return of Foreign Trust With a U.S. Owner,” when they

Megan L. Brackney Participates In A Panel Entitled “Representing The Promoter – Fighting On Multiple Fronts” At The ABA Virtual 2021 Midyear Tax Meeting

On January 27, 2021, Megan L. Brackney participates in a panel entitled “Representing the Promoter – Fighting on Multiple Fronts” at the ABA Virtual 2021 Midyear Tax Meeting. Description: The IRS has ramped up its efforts to combat abusive or potentially abusive tax schemes. Enhanced coordination and collaboration is providing

Megan L. Brackney Teaches A Course Entitled “The Nuts and Bolts of Tax Penalties: Analyzing Types of Penalties, Potential Defenses to Penalties, and Procedures for Challenging Penalties” For Lawline

On December 7, 2020, Megan L. Brackney teaches a course entitled “The Nuts and Bolts of Tax Penalties:  Analyzing Types of Penalties, Potential Defenses to Penalties, and Procedures for Challenging Penalties” For Lawline. Course description: This program discusses tax penalties assessed against taxpayers, defenses to penalties, and the procedures for

Megan L. Brackney Participates In A Panel Entitled “Problems Facing Taxpayers With Foreign Information Return Penalties (Statute of Limitations, Jurisdictional Concerns, Flora, etc.)” At The University of San Diego 16th Annual USD School of Law-Procopio International Tax Law Institute via Zoom

On November 12, 2020, Megan L. Brackney participates in a panel entitled “Problems Facing Taxpayers with Foreign Information Return Penalties (Statute of Limitations, Jurisdictional Concerns, Flora, etc.)” at The University of San Diego 16th Annual USD School of Law-Procopio International Tax Law Institute via Zoom. Panel information: The IRS continues