Civil tax penalties can have a significant impact, but practitioners have a range of administrative, procedural and statutory defenses available. Examine key penalty provisions, including failure-to-file and failure-to-pay penalties, accuracy-related penalties, reasonable cause defenses and the IRS’s new Automatic Exemption from Penalty (AEP) process. Also learn a practical framework for identifying and documenting penalty defenses, including situations where reasonable cause is not available.
DESIGNED FOR
CPAs and accounting professionals in public practice and industry.
BENEFITS
- Understand how the IRS’s new Automatic Exemption from Penalty (AEP) process changes the way certain penalty relief is applied.
- Identify key defenses to failure-to-file, failure-to-pay and accuracy-related penalties, including reasonable cause and professional reliance.
- Recognize procedural requirements that may provide an opportunity to challenge an IRS penalty assessment.
- Apply a practical, five-step framework for evaluating, documenting and defending civil tax penalties.
HIGHLIGHTS
- Overview of civil tax penalties and key penalty provisions under the Internal Revenue Code
- Failure-to-file and failure-to-pay penalties, including rates, limitations and penalty stacking
- Accuracy-related penalties, reporting standards and supervisory approval requirements
- Administrative and statutory penalty relief, including the AEP process, reasonable cause and professional reliance
- Procedural and substantive approaches to evaluating, documenting and defending penalty assessments