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Zhanna Ziering Addresses FBAR Investigations and Litigation on Strafford Webinar

September 24, 2020, 1:00 PM EDT
Panelist:Zhanna A. Ziering
Program:FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, FBAR Defense Strategies, Recent Cases, Penalties
Event Sponsor:Strafford Publications
Registration:Click Here To Register


The IRS is aggressively enforcing compliance with U.S. tax rules and foreign accounts compliance. This is particularly true in the case of failure to file a FinCen Form 114 (FBAR), where the IRS has had several high-profile court victories upholding penalties for willful failure to file.

Taxpayers with international tax reporting obligations suffer from rigorous compliance and enforcement efforts and overly complicated rules and regulations. The IRS is increasingly more effective at identifying non compliant taxpayers focusing on (1) reporting issues with respect to foreign accounts, assets, and investments, and (2) foreign income generated from foreign businesses, gifts, inheritances, mutual funds, and other passive investments.

Significant FBAR penalties, in particular, had been a powerful enforcement tool for the IRS. Possessing an in-depth understanding of FBAR filing rules and regulations will assist counsel and tax advisers in helping taxpayers maintain compliance and avoid FBAR investigations that may result in severe civil and criminal penalties.

Listen as our panel explains FBAR filing and reporting requirements, navigating FBAR examination and litigation, the evolution of the "non-willful" standard, and managing administrative appeals, the federal district court, and U.S. Court of Federal Claims litigation.


  1. Critical compliance issues and resolution options
  2. Navigating the FBAR examination and assessment process and administrative appeals
  3. Penalties and FBAR defense strategy
  4. Litigation; recent cases and IRS enforcement actions

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