Abajian Law attends 29th Annual Tax Controversy Institute

Vic Abajian, attended the annual Tax Controversy Institute on October 22, 2013. This is his 12^th year attending. The institute brings together sophisticated tax practitioners from the federal government, judiciary, and private practice to discuss and debate the procedures, policies, and strategies that are involved in resolving difficult tax controversy issues.

Future challenges of the IRS, federal employment taxes, tax collection techniques, changes to Circular 230, undeclared foreign financial accounts, penalties and sensitive tax issues were some of the topics examined during the conference. The Internal Revenue Service is dealing with an increasing caseload, complex changing tax laws and globalization. Some of the concerns raised were in regards to whether technological advances can sufficiently aid the IRS in dealing with such changes. IRS’ enforced collection efforts, Due Process and Offers in Compromise were also reviewed.

Some important topics covered in the conference were undeclared foreign financial accounts and policies behind penalties and reasonable cause standard. Under FATCA, the law passed in March 2010, United States’ government now has the authority to collect account information from international financial institutions on US taxpayers who are suspected of hiding their income overseas. However, individuals can evade heavy penalties or imprisonment by disclosing their foreign accounts to the IRS under the OVDP program. Details about the Offshore Voluntary Disclosure Program were discussed. Experienced practitioners also reviewed issues of good faith, civil penalties, adequate disclosures, penalty abatement considerations and application of the Section 6676 penalty regarding claims for refund.