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' role in identifying potential foreign information reporting issues, correcting filing deficiencies, and navigating the disclosure process.
Outline
- Identifying foreign information noncompliance scenarios
- Streamlined disclosure program for non-willful delinquency
- SDOP for U.S. resident
- SFOP for non-U.S. resident
- Program for willful delinquency
- Delinquent international information return submission procedures
- Delinquent FBAR submission procedures
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?
- How significantly has the amnesty landscape changed now that OVDP is no longer an option?
- What documentation and submissions must accompany a corrective filing?
Faculty
Brian Gardner, J.D., LL.M.
Partner
Asbury Law Firm
Mr. Gardner focuses his practice on tax controversy and litigation matters. He represents taxpayers in all phases of... | Read More
Mr. Gardner focuses his practice on tax controversy and litigation matters. He represents taxpayers in all phases of tax litigation including U.S. District Courts, U.S. Tax Court, United States Courts of Appeals, and the Georgia Tax Tribunal. Brian has extensive experience working with the IRS and the Georgia Department of Revenue in matters concerning, among other things, defense of conservation easements, passive activity losses, net operating losses, estate taxes, 831(b) captive insurance, promoter penalties, employment taxes, and international tax issues.
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David J. Moise
Partner
Blank Rome
Mr. Moise has more than 30 years of experience providing services in the area of tax and tax controversy. His practice... | Read More
Mr. Moise has more than 30 years of experience providing services in the area of tax and tax controversy. His practice focuses on federal, state, and local tax examinations, appeals, and litigation, and federal and multi-state voluntary disclosure agreements. In addition, he has extensive experience in relation to tax collection procedures, including tax liens and levies, as well as collection administrative appeals, installment agreements, and offers in compromise.
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Jeffrey M. Rosenfeld, Esq.
Partner
Blank Rome
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.
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