
This in-depth program provides comprehensive coverage of the tax implications for U.S. taxpayers with foreign income and assets. Participants will explore the complexities of reporting foreign income, compliance requirements for foreign asset disclosure, and strategies for minimizing tax liabilities under international tax treaties. The program addresses key areas such as the Foreign Account Tax Compliance Act (FATCA), the Foreign Bank and Financial Accounts (FBAR) reporting, and the taxation of foreign trusts. It also includes a discussion on the tax treatment of foreign earned income and the benefits of the Foreign Earned Income Exclusion (FEIE) and Foreign Tax Credit (FTC). The session features practical examples and case studies to help attendees navigate the intricacies of international taxation effectively and ensure compliance with both U.S. and foreign tax laws.
encouraged to accept a pro bono tax controversy case assignment from NYCLA, an ABA-sponsored Tax Court Pro program or a NY or NJ low-income Tax Clinic.

Frank Agostino is one of the most accomplished tax controversy attorneys in the country, with more than four decades of litigation experience and a string of landmark victories that have reshaped IRS enforcement and Tax Court procedure — including Commissioner v. Zuch before the U.S. Supreme Court (2025) and Chai v. Commissioner in the Second Circuit (2017).
Because of Frank’s stellar reputation in the tax bar, he has been ranked in Chambers in Band 1 for Tax: Fraud Nationwide (USA) and in Band 1 for High Net Worth Private Client: Tax.
A former IRS District Counsel attorney and Special Assistant U.S. Attorney, Frank has also taught tax controversy at Seton Hall and Rutgers Law, and currently serves on the Advisory Board of the Journal of Tax Practice and Procedure.