The IRS has been aggressively assessing penalties for late-filed foreign information returns against taxpayer, many of whom have voluntarily attempted to correct past non-compliance.
This program discusses the basic filing requirements for foreign information returns and the penalties that the IRS most commonly assesses, the reasonable cause defense to these penalties, and the procedures to challenging the assessments.
Presenter Bio
Megan L. Brackney has a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. An expert in the interplay between civil and criminal tax controversies, Ms. Brackney develops innovative strategies to resolve compliance concerns, civil audits, and criminal investigations.
Ms. Brackney also advises clients on tax issues that arise in other contexts, such as business and matrimonial disputes, and she represents clients in litigation in the U.S. Tax Court and federal district courts.
Ms. Brackney has been recognized by the “New York Super Lawyers” since 2012.
Prior to joining Kostelanetz LLP in 2004, Ms. Brackney was an Assistant United States Attorney for the Southern District of New York. She also served as an Assistant Attorney General for the State of Missouri.
Ms. Brackney is an adjunct professor at New York University School of Law.
Ms. Brackney is currently the Vice Chair of Committee Operations for the American Bar Association Section of Taxation, a member of the Executive Committee of the New York State Bar Association Section of Taxation and a member of the American College of Tax Counsel.
Ms. Brackney has previously served as a Council Director for the American Bar Association Section of Taxation, the Chair of the Taxation Committee of the New York County Lawyers’ Association, and the Chair of the Individual and Family Taxation Committee of the American Bar Association, Tax Section. She received the American Bar Association Tax Section’s John S. Nolan Fellowship for 2008-2009.
Ms. Brackney received her J.D. from the University of Kansas School of Law and her LL.M. in Taxation from New York University, and is a member of the Board of Governors for the University of Kansas School of Law.
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