Tax Attorneys and Shareholders Igor S. Drabkin and David J. Warner will be speaking in an upcoming Strafford live webinar, “FBAR 2023 Update: Filing Requirements, Recent Cases, Deadlines, Extension, Penalty Resolution, and Waiver Provisions” on Wednesday, November 1, 2023, from 10:00 am to 11:30 am Pacific time.

Foreign bank accounts remain a top priority for the IRS, including imposing penalties in the millions of dollars against taxpayer who do not timely file a complete Report of Foreign Bank and Financial Accounts (FBAR). In 2023, the IRS continued a 10+ year trend of listing offshore issues, including FBARs, among its Dirty Dozen list of top tax scams. While the form and filing requirements remain in place, FinCEN and the IRS have extended some filing deadline protections to benefit taxpayers required to disclose foreign-based financial account balances.  In addition, the recent U.S. Supreme Court decision in Bittner v. United States provided some clarity to the IRS’s ability to enforce nonwillful penalties.

FBAR remains a complicated reporting obligation and the IRS will cross-reference FBAR information with other tax filings, as well as information disclosures from other sources such as foreign financial institutions. This makes failure to accurately report assets on the FBAR potentially very costly for U.S. taxpayers, even with the extension provisions of the new regulations.

Igor and David will review these and other key issues:

  • When can corporate officers’ stake in foreign accounts trigger reporting responsibilities?
  • What is the latest in the IRS and FinCEN enforcement activity?
  • What are the options for companies required to file an FBAR and have not?
  • How do Form 8938 filing requirements intersect with FBAR?

After our presentations, we will engage in a live question and answer session with participants so we can answer your questions about these important issues directly.  We hope you’ll join us.  For more information or to register click here. 

Igor S. Drabkin is a Certified Tax Law Specialist by the State Bar of California. He devotes his skills and experience to representation of clients who are in disputes, or have compliance issues, with the Internal Revenue Service and State taxing authorities, both administratively and in court. He litigates cases in all federal and state courts, including U.S. Tax Court, U.S. District Court, Court of Federal Claims and U.S. Bankruptcy Court. In addition, Igor represents clients in tax audits, fraud and criminal investigations, administrative appeals, tax collection and bankruptcy matters. Igor also has extensive experience representing clients with offshore tax compliance issues, including Offshore Voluntary Disclosure, FBAR audits and Grand Jury investigations related to foreign bank accounts.  Igor also was a Senior Trial Attorney with the IRS Office of Chief Counsel.

David J. Warner practices in all aspects of tax controversy including tax audits, collection defense, and tax litigation.  Before joining Holtz, Slavett & Drabkin, David was a Senior Trial Attorney with the IRS Office of Chief Counsel in Laguna Niguel for 9 years.  As an IRS attorney, he handled over 500 cases before the U.S. Tax Court, including the most complex domestic and international cases.  As is relevant to this presentation, David was the Lead Counsel of the IRS FBAR Cadre in Southern California, and David advised local IRS Special Enforcement Program (SEP) and Large Business & International (LB&I) International Individual Compliance (IIC) revenue agents on FBAR matters.  David also has handled FBAR litigation in the U.S. District Court for the Central District of California.  David was an Adjunct Professor of Law at University of California Irvine School of Law, Chapman University Fowler School of Law, and Loyola Law School, where he taught courses on tax practice and procedure, partnership tax, bankruptcy tax, and corporate tax.

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 and offshore matters.  To schedule a consultation, please contact us at (310) 550-6200 or (949) 999-6606.