IRS International Penalties After Farhy



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Credit Details
Credit Hours:
Specialty Area:
Taxation Law
Credit Type:
Original Air Date:
May 18, 2023
Accredited In:

You may be able to self apply for credits in states not listed. BHBA provides CLE accreditation as described above. 

About the Program

On April 3, 2023, the United States Tax Court, in Farhy v. Commissioner held that the IRS has no authority to assess and collect penalties under IRC Section 6038(b)(1) and (2), for failing to file Form 5471. For about 15 years the IRS has made foreign reporting penalties a cornerstone of its enforcement. In the last several years, taxpayers have been assessed penalties without any review prior to assessment. The Farhy decision provides hope for taxpayers that change is coming. Learn what the Farhy case means for foreign penalties, what other penalties the decision might apply to, and how to address previous penalties that might be affected by the Farhy case. The panel features Edward Robbins, Jr., Mr. Farhy?s attorney, and Zhanna Ziering, and Jonathan Kalinski, two experts in international penalties.

Meet the Speakers
Jonathan Kalinski


Principal Hochman Salkin Toscher Perez P.C.

Jonathan Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. 

Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters. Prior to joining the firm, he served as a trial attorney with the IRS Office of Chief Counsel litigating Tax Court cases and advising Revenue Agents and Revenue Officers on a variety of complex tax matters.

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Zhanna Ziering


Member Moore Tax Law Group

Zhanna A. Ziering, a tax controversy and litigation attorney, is a Member in the Firm’s New York office. Ms. Ziering’s practice focuses on representing individual and entity clients in civil and criminal tax disputes with federal and state governments as well as in regulatory proceedings. She defends both individual and entity taxpayers before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators. 

Ms. Ziering advises taxpayers in connection with various tax issue, including those arising in connection with domestic and offshore income and assets, cryptocurrency, and U.S. tax and regulatory reporting requirements. She approaches each of her client engagements with empathy and kindness and develops a strategy for dispute resolution by taking the client’s views, needs, and resources into consideration. When faced with alternatives for dispute resolution, Ms. Ziering discusses the various available options, and the benefits and drawbacks of each such option, with the clients and works together with them to develop the approach tailored to that particular client and situation. 

Ms. Ziering strives to resolve every tax dispute that her clients are facing amicably and efficiently while zealously advocating on her clients’ behalf. Her significant experience in representing clients in various stages of a tax dispute allows her to aptly navigate the procedural hurdles and achieve best results possible under the circumstances for each client. A well-regarded member of the legal community, Ms. Ziering is actively engaged in American Bar Association, Section of Taxation. She currently serves as the Vice Chair of Court Practice and Procedure Committee.\ Ms. Ziering is also a sought-after speaker and writer on various topics relating to tax controversy and litigation. She is a co-author of the Bloomberg BNA’s Tax Management Portfolio, Report of Foreign Bank and Financial Accounts.

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Edward Robbins, Jr.


Principal Hochman Salkin Toscher Perez P.C.

Edward M. Robbins, Jr. has been a principal with the Hochman Salkin Toscher & Perez, P.C., a tax boutique law firm in Beverly Hills, California since 2004. Before entering private practice, Mr. Robbins was an Assistant United States Attorney with the Central District of California, Tax Division. Mr. Robbins left the government after ten years serving as the Chief of the Tax Division, six years as Assistant Division Chief, nine years as Assistant United States Attorney, and 4 years as a District Counsel attorney with the IRS Chief Counsel office in Los Angeles. As Chief of the Tax Division, Mr. Robbins supervised the lawyers in the Tax Division and handled a full caseload specializing in complex, civil and criminal tax litigation. 

Mr. Robbins has a well-deserved reputation as a leading member of the civil and criminal tax bar in the United States as the result of extensive experience representing both the United States of America and taxpayers. Mr. Robbins’ credentials include extensive experience in conducting dozens of complex financial investigations as the result of his career as Assistant United States Attorney. His experience includes numerous grand jury investigations and civil administrative investigations for the United States. These investigations concerned individuals, business enterprises, partnerships, limited liability companies, and corporations. 

As a nationally recognized tax professional, Mr. Robbins is often called upon to participate in programs dealing with civil and criminal tax practice, procedure, controversy and litigation matters, before government agencies and professional organizations. He is the co-author of PLI’s two volume tax treatise, IRS Practice and Procedure Desktop. Mr. Robbins has also been honored to serve as an adjunct law professor with Loyola Law School and Golden Gate University School of Law. He has written, lectured and taught legal topics on U.S. tax procedure. He is a member of the American Bar Association, Tax Section, California State Bar’s Taxation Section, Beverly Hills Bar Association, Taxation Section, Los Angeles County Bar Association, Taxation Section and American College of Tax Counsel. Mr. Robbins received numerous awards from the Department of Justice, the Internal Revenue Service Criminal Investigation and the IRS Chief Counsel. Mr. Robbins was a regular Trial Instructor at the Attorney\ General’s Advocacy Institute from 1988 to 2004.

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