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At Brotman Law, we focus on providing as much as we can for our clients. That’s why we created Brotman University – your one stop shop for comprehensive tax law resources.
FBAR Penalty Appeals and Compliance Programs
If you have been penalized by the IRS for FBAR violations, there is hope. We explore some of the penalty appeals and compliance programs available to taxpayers to avoid excessive fines and jail time.
Penalties For Non-Willful Violations
Did you know you are required to file a FBAR form if you have overseas accounts? If not, you could be in trouble with the IRS. Find out how to prove your innocence and avoid steep penalties.
Penalties For Willful Violations
If you knowingly did not file a FBAR form to disclose your foreign financial dealings, expect costly IRS penalties or worse. Take some advice from a top tax attorney on how to set things right.
Other Important Filing Requirements For Those With International Interests
International tax compliance is complicated. Learn from a top U.S. tax attorney which forms you need to file if you have international interests to stay off the IRS’ radar.
Filing Requirements For Those With An Interest In Foreign Corporations, Form 5471
Having interest in foreign corporations is not illegal. Failing to disclose it is. A top tax attorney explains why you need to file IRS Form 5471.
Filing Requirements For Those With Foreign Assets, Form 8938
An experienced tax attorney explains filing requirements for those with foreign assets and how to complete Form 8938.
Filing Requirements For Trusts & Gifts: Form 3520/3520A
Any income you receive from foreign trusts needs to be disclosed to the IRS. The same goes for bequests or gifts. Learn about the filing requirements for IRS Form 3520.
International Tax Considerations For Individual 1040 Filings
When you file your individual 1040 tax form, do not forget any international tax considerations you have. Confused? Keep reading and we will show you what to do to avoid problems with the IRS.
What Is Foreign Bank Account Reporting (FBAR)?
If you have money in overseas bank accounts, you have not escaped IRS scrutiny. If you have not heard of Foreign Bank Account Reporting (FBAR), read this chapter to understand the consequences of noncompliance.
Types Of Foreign Income That Trigger Filing Requirements
If you are a nonresident but earn income from U.S. sources, then you owe taxes to the IRS. To find out which foreign income triggers filing requirements, read this advice from a top U.S. tax attorney.
U.S. Taxpayers & Considerations For Dual-Status Tax Filers
Whether you are moving to or away from the U.S., you could face U.S. tax consequences. The big question is if the IRS deems you a U.S. citizen. We have answers for dual-status filers.
The Ultimate Guide To International Taxation
International Tax Compliance — the U.S. Departments of Justice and Treasury are joining forces with the IRS. Are you on their list?
U.S. Taxpayers and Considerations for Dual-Status Tax Filers
International tax issues are very complex and if errors are made, the penalties can be quite steep.
FBAR Penalty Appeals and Compliance Programs
If you have been penalized by the IRS for FBAR violations, there is hope. Learn options available to taxpayers to avoid excessive penalties and jail time.
Establishing Residency or Domicile in California Can Be Taxing
Did you know that a 2020 California FTB guideline states “if you are impacted by the COVID-19 pandemic, it is one of the factors we will consider as we apply the general rules for residency and income sourcing?”
Penalties for Non-willful Violations
Did you know you are required to file a FBAR form if you have overseas accounts? If not, you could be in trouble with the IRS.
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The Audit Process Step by Step
Here's what happens from the moment you receive an audit notice to resolution:
- Notice received — The IRS sends a letter explaining what they're examining and what documentation they need
- Power of Attorney filed — We sign Form 2848, which means the IRS talks to us, not you
- Document review — We review every document before anything goes to the IRS. We provide exactly what's needed — nothing more
- Examination — The IRS reviews your records. For office and field audits, we attend all meetings in your place
- Proposed adjustments — If the IRS wants to make changes, they issue a written proposal. We review it line by line
- Negotiation or appeal — We challenge anything we disagree with. If we can't resolve it at the exam level, we take it to appeals
- Resolution — Case closed. We make sure you understand the outcome and what it means going forward
Why You Need Professional Representation
Here's the reality: anything you say to the IRS can be used against you. Even an innocent statement can be misinterpreted, taken out of context, or used to expand the scope of your audit.
Your CPA probably filed your return. That's great. But filing a return and defending one are two completely different skills. You wouldn't send your dentist to perform heart surgery — the same logic applies.
A qualified tax attorney knows IRS procedures inside and out, understands the legal standards the IRS must meet, and knows exactly how to position your case for the best possible outcome.
Appeals & Next Steps
If you disagree with the audit results, you have the right to appeal. The IRS Office of Appeals is independent from the examination division, and they settle the majority of cases they hear.
We've won over 100 appeals by building cases that are thoroughly documented and legally sound. The key is presenting a clear, well-organized argument that makes it easier for the appeals officer to rule in your favor.
If appeals doesn't resolve it, the next step is Tax Court. We're prepared for that too, but in our experience, most cases settle well before they get to trial.
How to Prevent Future Audits
Once your audit is resolved, the last thing you want is another one. Here's what we recommend to minimize your risk:
- Keep meticulous records — especially for deductions and business expenses
- Report all income — even if you didn't receive a 1099
- File on time, every time
- Use actual calculated figures rather than round numbers — while not a major audit trigger on its own, it's a best practice that signals accuracy in your records
- Work with a qualified tax professional who understands your situation
- Consider a proactive tax strategy engagement to optimize your structure and reduce risk
Want to make sure this doesn't happen again? After resolving your audit, we can help restructure your taxes to minimize future risk. It's the other side of what we do — and it's just as important as the defense. Learn about our tax strategies →
