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 webinar will provide CPAs and tax advisers with a practical guide to navigating the amnesty programs that are 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 the role of compliance professionals and advisers in identifying potential foreign information reporting issues, correcting filing deficiencies, and navigating the disclosure process.
- Identifying foreign information noncompliance scenarios
- Streamlined disclosure program for non-willful delinquency
- SDOP for U.S. resident
- SFOP for non-U.S. resident
- New program for willful delinquency
- Delinquent international information return submission procedures
- Delinquent FBAR submission procedures
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?
- How significantly has the amnesty landscape changed now that OVDP is no longer an option?
- What documentation and submissions must accompany a corrective filing?
Saul Ewing Arnstein & Lehr
Mr. Fayne assists companies and individuals, nationally and internationally, on corporate and tax issues. As a... | Read More
Mr. Fayne assists companies and individuals, nationally and internationally, on corporate and tax issues. As a corporate attorney, he routinely advises management or in-house general counsel on various legal matters affecting their day-to-day corporate activities. Mr. Fayne is also a tax attorney who helps businesses and individuals with tax controversies before the IRS and tax planning both domestically and internationally. He also handles a variety of white-collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money laundering and offshore tax compliance. Mr. Fayne’s knowledge of tax law is informed by his former role as a Special Assistant U.S. Attorney with the Department of Treasury's IRS.Close
Mr. Gardner focuses his practice on federal, state and international tax controversy and tax planning matters. He... | Read More
Mr. Gardner focuses his practice on federal, state and international tax controversy and tax planning matters. He represents taxpayers in IRS audits, appeals, refund claims and in U.S. Tax Court. Mr. Gardner has experience representing individuals and companies in tax controversy and litigation matters concerning, among other things, defense of conservation easements, passive income losses, net operating losses, innocent spouse claims, employment taxes, trust fund recovery penalties and offshore voluntary disclosures.He regularly consults with businesses in a variety of industries including e-commerce, manufacturing, technology and health care on federal and state tax planning issues.Close
Jeffrey M. Rosenfeld, Esq.
Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax... | Read More
Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax matters including domestic and international tax matters, state and local tax planning, tax-efficient structuring of domestic and international mergers, acquisitions, divestitures, reorganizations, spin-offs, redemptions and liquidations, formation, operation and acquisition of Subchapter S Corporations, partnerships and limited liability companies. He counsels clients regarding undeclared foreign bank accounts, including “FBAR” reporting obligations.Close
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CPE On-DemandSee NASBA details.