Holtz, Slavett & Drabkin tax attorney, David J. Warner, will be a speaker at the USC Gould School of Law 2019 Tax Institute, which will be held in Los Angeles on January 28-30, 2019. David will be a speaker on the panel, “Contesting and Litigating International Reporting Penalties.”
Over the past 10 years, the Internal Revenue Service (IRS) has placed significant resources and considerable focus on taxpayer’s offshore activities, especially foreign bank accounts, foreign trust, and foreign corporations. As a part of this focus, the IRS and the Department of Justice have asserted and defended significant penalties involving the Report of Foreign Bank Accounts (FBAR) and other international information return penalties. This panel will discuss the IRS’s assessment and collection of these penalties and the best practices for contesting these penalties both administratively and through various courts.
To learn more about the USC Gould School of Law 2019 Tax Institute, click here.
David J. Warner practices in all aspects of tax controversy including tax audits, collection defense, and litigation in the U.S. Tax Court, U.S. District Court, and the Court of Federal Claims. As is relevant to this panel, David currently represents individuals in FBAR litigation in U.S. District Court and international information return penalty audits before the Internal Revenue Service.
Before joining Holtz, Slavett & Drabkin, David was a Senior Trial Attorney with the IRS Office of Chief Counsel for 9 years. He litigated over 500 cases before the U.S. Tax Court, including the most complex cases with up to $25 million in taxes and penalties at issue. David was the lead counsel of the IRS Southern California FBAR Cadre, approving hundreds of millions of dollars in FBAR penalties and coordinating FBAR penalty litigation in Southern California. David also advised the local Special Enforcement Program (SEP) and Large Business & International (LB&I) International Individual Compliance (IIC) revenue agents on complex domestic and international issues, including international information return penalties.
Holtz, Slavett & Drabkin, APLC is a tax controversy and tax litigation law firm consisting of former IRS trial attorneys. We represent taxpayers in all aspects of tax disputes with the IRS and state tax authorities, including FBAR litigation and international information return penalties. To schedule a consultation, please contact us at (310) 550-6200.