Voluntary Disclosure of Foreign Assets: Current Challenges for Noncompliant U.S. Taxpayers
Options for Compliance, Avoiding Penalties and Potential Criminal Prosecution
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide counsel and tax advisers with guidance on available options for reporting foreign assets of noncompliant U.S. taxpayers. The panel will discuss Foreign Bank Account Report (FBAR) requirements, alternative compliance options after the IRS' termination of the Offshore Voluntary Disclosure Program (OVDP), current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.
Outline
- Overview of the disclosure requirements of foreign accounts and assets
- What is willful blindness?
- A Deep Dive into the IRS’ Non-Willful Disclosure Programs
- Best practices for advising the noncompliant U.S. taxpayer
- Are quiet disclosures a viable option?
- What are the best practices in determining which voluntary disclosure program benefits the client?
Benefits
The panel will review these and other critical issues:
- What options are available to clients?
- What are the requirements of each IRS’ voluntary disclosure program?
- What are the penalties associated with a client’s failure to participate in these voluntary disclosure programs?
Faculty
Deborah J. Jacobs
Owner
The Law Office of Deborah J. Jacobs
Ms. Jacobs represents clients worldwide on international tax matters under U.S. tax laws including cross-border... | Read More
Ms. Jacobs represents clients worldwide on international tax matters under U.S. tax laws including cross-border transactions, tax treaty planning, foreign tax credit planning, repatriation and deferral planning, and international tax compliance. Her clients are individuals, foreign companies and entities, and individuals or financial institutions doing business or residing in the United States, U.S. companies and entities, and financial institutions doing business or residing abroad.
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Dennis N. Brager, Esq.
Certified Tax Specialist
Brager Tax Law Group
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and... | Read More
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and tax controversy matters. Before founding the Brager Tax Law Group, a Los Angeles-based tax litigation and tax controversy law firm, he was a senior trial attorney for the Internal Revenue Service’s Office of Chief Counsel. Since 2008 he has represented several hundred clients with offshore accounts. He also represents clients on a variety of issues, including criminal and civil tax fraud, tax audit and appeals, payroll and sales tax problems, tax preparer penalties, innocent spouse defenses, offers in compromise, installment payment agreements, Office of Professional Responsibility (“OPR”) defenses and more.
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