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

or call 1-800-926-7926
Program Materials

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.

Description

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.

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Outline

  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

Benefits

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?

Faculty

Brager, Dennis N.
Dennis N. Brager, Esq.

Brager Tax Law Group

Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and...  |  Read More

Jacobs, Deborah J.
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

Rubinstein, Asher
Asher Rubinstein

Partner
Rubinstein and Rubinstein

Mr. Rubinstein concentrates his practice in domestic and international asset protection, wealth preservation, tax...  |  Read More

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