Correcting Foreign Information Reporting Noncompliance: Voluntary Disclosure Programs
Navigating Penalty Abatement for Failure to File Forms 5471, 5472, FATCA, and FBAR
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide CPAs and tax advisers with a practical guide to navigating the amnesty programs available to rectify a client's failure to properly file required international information forms such as the FBAR, Form 8938, and Forms 5471 and 5472. The panel will focus on compliance professionals' and advisers' roles in identifying potential foreign information reporting issues, correcting filing deficiencies, and navigating the disclosure process.
Outline
- Correcting Foreign Reporting Noncompliance - Introduction
- IRS Criminal Investigation Voluntary Disclosure Practice (VDP)
- Streamlined disclosure program for non-willful delinquency
- Streamlined Domestic Offshore Procedures for U.S. resident
- Streamlined Foreign Offshore Procedures for non-U.S. resident
- Delinquent international information return submission procedures
- Delinquent FBAR submission procedures
- Evaluating compliance options
- Foreign information noncompliance scenarios
Benefits
The panel will discuss these and other relevant topics:
- What foreign reporting forms are subject to foreign tax reporting penalties?
- What are the penalty structures for non-willful and willful failure when other violations are in place?
- What amnesty programs are available to rectify a client's past failures?
- What criteria should a tax professional consider when advising a client on the best option to correct noncompliance?
- What documentation and submissions must accompany a corrective filing?
Faculty
Mishkin Santa, JD, LLM, TEP
Principal, Director of International Tax
The Wolf Group
Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift &... | Read More
Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift & trust tax compliance, FBAR Assistance, foreign trust tax compliance, exit tax planning, EB-5 investor program, international assignment structuring and planning, offshore voluntary disclosure programs, foreign corporation (Subpart F, Transfer Pricing, E&P Studies), and asset protection planning. His client base includes U.S. citizens living overseas, U.S. nonresidents, EB-5 investors, U.S. domestic individuals and families, international businesses, international based families with investments in multiple jurisdictions and tax residency in multiple jurisdictions, U.S. citizens or residents who are beneficiaries of foreign trusts and who will receive gifts or inheritances from non-US persons, and trustees of trusts with U.S. grantors or U.S. beneficiaries.
David J. Warner
Tax Attorney, Shareholder & Managing Principal
Holtz, Slavett & Drabkin
Mr. Warner is a Tax Attorney and the Managing Attorney of the Orange County Office of Holtz, Slavett &... | Read More
Mr. Warner is a Tax Attorney and the Managing Attorney of the Orange County Office of Holtz, Slavett & Drabkin. He has over 10 years of experience practicing in all aspects of tax controversy including tax audits, collection defense, and litigation in the U.S. Tax Court, U.S. District Court, and the Court of Federal Claims. He represents taxpayers in cases involving income tax, estate tax, gift tax, employment tax, collection issues, innocent spouse, penalties, and bankruptcy tax issues. He also represents taxpayers before the California Franchise Tax Board (FTB), Department of Fee and Tax Administration (CDTFA, formerly State Board of Equalization (BOE)), and Employment Development Department (EDD). He has particular expertise in tax matters involving individuals and small businesses, the examination of partnerships and S corporations, and offshore tax compliance issues, including the Report of Foreign Bank and Financial Accounts (FBAR), civil fraud, and offshore information return penalties.
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