Correcting Foreign Information Reporting Noncompliance: Voluntary Disclosure Programs

Navigating Penalty Abatement for Failure to File Forms 5471, 5472, FATCA and FBAR

A live 110-minute CPE webinar with interactive Q&A


Tuesday, August 15, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT


This webinar will provide CPAs and tax advisers with a practical guide to navigating the process of requesting abatements of IRS penalties due to client failure to properly file required international information forms such as the FBAR, Form 8938, and Forms 5471 and 5472. The panel will focus on the role of compliance professionals and advisers in identifying potential foreign information reporting issues, correcting filing deficiencies, and navigating various penalty abatement relief programs.

Description

The IRS continues to increase its attention and resources to foreign tax compliance reporting by U.S. persons over the past several years. Tax reporting of international accounts and activities can be complex, and failure to file foreign tax informational forms typically trigger more severe penalties than failure to file most required domestic tax forms.

The Internal Revenue Code sets penalties for failure to file Forms 5471 and 5472 at $10,000 per unfiled return. Additionally, Code Section 6038(c) provides for a reduction of 10% or more of foreign taxes available for credit under Sections 901, 902 and 960.

Likewise, the penalties for failure to file the FBAR (FinCEN Form 114) range from $10,000 for non-willful failure to the greater of $100,000 plus 50% of the account balance at the time of the violation for willful noncompliance.

Tax advisers and compliance professionals are often the first parties to discover possible noncompliance with these complex foreign information requirements and are in the best position to seek remedy in the form of penalty abatement.

Advisers serving clients with offshore assets must be able to identify instances where clients have risk due to missing or incorrect foreign information filings. They should also be fully knowledgeable of the requirements and processes for requesting abatements of penalties for failure to file required foreign tax information.

Listen as our experienced panel provides best practices for documenting and filing requests for abatement of foreign tax penalties.

Outline

  1. Identifying foreign information noncompliance scenarios
  2. Delinquent information return program
  3. Streamlined disclosure program
    1. SDOP for U.S. resident
    2. SFOP for Non-U.S. resident
  4. Offshore voluntary disclosure program (OVDP)
  5. What filings and submittals are required for penalty abatement requests
  6. Current IRS procedures for evaluating voluntary submittals

Benefits

The panel will discuss these and other important 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 are the standards for “reasonable cause” abatement?

  • What documentation and submissions must accompany a corrective filing or penalty abatement request?

  • What is the IRS penalty abatement decision tree model and how does it apply to requests to abate foreign tax penalties?

Learning Objectives

After completing this course, you will be able to:

  • Recognize scenarios and examples of foreign information reporting noncompliance
  • Identify the various disclosure programs and remedial options to bring previously non-filing taxpayers into compliance on foreign asset information reporting
  • Discern the filing and documentation requirements for various disclosure programs and penalty abatement requests
  • Recognize the risks and potential benefits of the revised voluntary disclosure programs
  • Determine situations in which the taxpayer’s failure to disclose may be classified as “willful” by the IRS and other circumstances in which a taxpayer should engage legal counsel

Faculty

Joshua Ashman, CPA, Partner
Expat Tax Professionals, New York

Mr. Ashman is an international tax accountant. He counsels Americans abroad regarding filing their U.S. taxes. He specializes in expat-specific issues and complicated tax matters. He previously held a senior management position in the international tax practice of PwC.

Ephraim Moss, Esq., Partner
Expat Tax Professionals, New York

Mr. Moss is a U.S. attorney specializing in international tax matters. He has extensive experience in counseling clients on matters such as cross-border tax structures, tax return treaty positions, expatriation matters and disclosure of foreign financial accounts. In recent years, he has focused his practice on assisting delinquent taxpayers utilize the various IRS disclosure programs and regularly represents client before the IRS. Prior to co-founding Expat Tax Professionals LLC, he held a managerial position in the international tax practice of Ernst & Young.

Nathan Mintz, Tax Counsel
Expat Tax Professionals, New York

Mr. Mintz is a U.S. attorney specializing in U.S. international tax matters. He has extensive experience in providing tax counsel to individuals and businesses with respect to U.S. inbound and outbound tax issues. In recent years, he has focused his work on tax issues affecting U.S. citizens living abroad, providing guidance under both U.S. domestic tax laws and international income tax treaties. Previously, he held a managerial position in the international tax practice of PwC.


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Live Webinar $147.00

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CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other attorneys or accountants. Specific knowledge and understanding of foreign asset information reporting requirements, particularly FATCA and FBAR/FinCen 114; familiarity with IRS audit procedures in examining foreign tax reporting, familiarity with voluntary disclosure programs.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


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This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: Printing and reviewing Program Outlines and materials.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: QAS Self-Study.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other attorneys or accountants. Specific knowledge and understanding of foreign asset information reporting requirements, particularly FATCA and FBAR/FinCen 114; familiarity with IRS audit procedures in examining foreign tax reporting, familiarity with voluntary disclosure programs.

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