FBAR and U.S. Tax Reporting and Compliance Requirements for Foreign Assets

Unraveling Foreign Asset and Income Reporting Obligations, Evaluating and Navigating the Offshore Voluntary Disclosure Program

Recording of a 90-minute CLE/CPE webinar with Q&A

Conducted on Tuesday, June 20, 2017
Recorded event now available

This CLE/CPE webinar will provide counsel and tax advisers with the tools necessary to navigate the new rules regarding FBAR and offshore voluntary disclosure programs (OVDPs) and assist clients with developing programs that provide workable solutions.


The IRS has made modifications over the past several years to the programs that allow for late reporting of undisclosed offshore assets. However the Service continually reaffirms its commitment to cracking down on U.S. taxpayers failing to disclose reportable foreign assets. The IRS is intensifying audits for foreign disclosures and tax advisers need to act quickly to take advantage of the benefits that may be applicable to their situations.

The two most significant programs aiding taxpayers with unreported foreign assets are the OVDP and the Streamlined Offshore Disclosure (SDP). Tax counsel and advisers must prepare now to assist clients on utilizing these programs. Clients will benefit from substantially reduced or no penalties for failure to report offshore accounts. However, counsel must be aware of the risks in each of the programs, as the penalties imposed on taxpayers that willfully fail to disclose are extremely harsh..

Counsel must first evaluate whether the disclosure program will help a taxpayer avoid increased IRS penalties. If so, counsel must guide the client in meeting the very specific information requirements of the OVDP application. The OVDP and SPD may end at any time without notice, so tax counsel should make client taxpayers aware of the potential tax and penalty savings from voluntary disclosure.

Listen as our experienced panel reviews the benefits and burdens of the revised programs and provides best practices in determining whether the new programs will benefit clients in the resolution of undisclosed offshore accounts.


  1. Delinquent information return program
  2. Streamlined disclosure program (SDP)
    1. U.S. resident
    2. Non-U.S. resident
  3. Offshore voluntary disclosure program (OVDP)
  4. Current IRS procedures for evaluating voluntary submittals


The panel will review these and other key issues:

  • Explaining to your client the value of not waiting until the IRS shows up on their doorstep to fix their offshore filing issues.
  • What is the statute of limitations on IRS assessment when taxpayers fail to timely meet their obligations to report their offshore assets?
  • What are the requirements for the Delinquent International Information Return Submission Procedures and the Delinquent FBAR Submission Procedures? When does a taxpayer qualify for these procedures?
  • In what ways can the SDOP/SFOP and OVDP programs benefit taxpayers?
  • What best practices should be implemented in determining how these voluntary disclosure programs can work for particular clients?
  • How should tax advisers best navigate the SDOP/SFOP or OVDP requirements?

Learning Objectives

Upon completing this seminar you will be able to:

  • Recognize the risks and potential benefits of the revised voluntary disclosure programs
  • Identify situations in which the taxpayer’s failure to disclose may be classified as “willful” by the IRS
  • Decide whether the SDP or the OVDP is a better option for a taxpayer with delinquent information reporting


Dennis N. Brager, Esq.
Brager Tax Law Group, Los Angeles

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.

Deborah J. Jacobs, Owner
The Law Office of Deborah J. Jacobs, New York

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.

Asher Rubinstein, Partner
Rubinstein and Rubinstein, New York

Mr. Rubinstein concentrates his practice in domestic and international asset protection, wealth preservation, tax planning and compliance, and related litigation. He has represented clients in a range of transactions including cross-border business ventures and investments, banking and finance. He has established domestic and offshore investment funds, and has provided advice and consultation regarding U.S. tax, regulatory and other governmental compliance.

EA Credit

Enrolled Agent credit processing is available for an additional fee per person.

EA Processing $5.00


CLE On-Demand - Streaming Video

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*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.

**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.

CLE On-Demand Video $297.00

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Note: Self-study CPE and EA credits are not offered on recorded events.

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Customer Reviews

The program alerted me to the issue and related potential questions and problems.

Jon Deane

Gaffey Deane & Talley

I liked the practical examples highlighting uncertainties and the ability to send in questions.

Richard Jacobson

Fowler White

It was a very good presentation of complex material, managed in an understandable format. The information will be useful in my practice.

Jay H. McDowell

Withers Bergman

The presenters were knowledgeable and able to intelligently answer questions.

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Mikunda, Cottrell & Co.

The speakers obviously had a thorough command of the subject matter.

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Updike, Kelly & Spellacy

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Tax Law Advisory Board

Robert S. Barnett


Capell Barnett Matalon & Schoenfeld

William H. Byrnes

Associate Dean, Special Projects

Texas A&M University Law

Robert A.N. Cudd

Senior Partner


Patrick Derdenger

Tax Partner

Steptoe & Johnson

Janice Eiseman


Cummings & Lockwood

Lynn Fowler


Kilpatrick Townsend & Stockton

Edward Froelich

Of Counsel

Morrison & Foerster

Daniel L. Gottfried


Hinckley Allen

J. Leigh Griffith

Partner and Practice Group Leader - Tax

Waller Lansden Dortch & Davis

L. Andrew Immerman


Alston & Bird

Mark S. Lange



Joseph C. Mandarino


Smith Gambrell & Russell

Lori Mathison

Partner, Cross-Border Transactions Tax

Fraser Milner Casgrain

Christian M. McBurney


Arent Fox

Suzanne Ross McDowell

Partner, Tax-Exempt Organizations

Steptoe & Johnson

Todd Reinstein

Partner, Corporate Tax and Due Diligence

Pepper Hamilton

Alex Sadler


Morgan Lewis

Susan Seabrook


Buchanan Ingersoll & Rooney

Peter Stathopoulos

Managing Director, State and Local Tax Practice

Bennett Thrasher

Eric Tresh

Partner & Co-Chair, State & Local Tax Practice

Sutherland Asbill & Brennan

Amanda Wilson


Lowndes Drosdick Doster Kantor & Reed

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