Latest FBAR Voluntary Disclosure and Impending FATCA Reporting Duties
Analyzing Pros and Cons of the IRS Offer; Data to Include on Form 8938
Recording of a 110-minute CPE webinar with Q&A
This teleconference will prepare advisors and taxpayers to analyze the potential benefits and drawbacks of the latest OVDI, to comply with FATCA reporting requirements, and to grasp the ramifications of other recent developments in the FBAR realm.
Outline
- The 2012 IRS OVDI
- Eligibility
- Potential penalties
- Pros and cons
- When expiration date will be set
- FATCA foreign account information reporting
- T.D. 9567 and Sect. 6038D rules
- Accounts and taxpayers covered
- Form 6038 and instructions
- Potential penalties
- Withholding rules
- Other recent developments
- IRS Fact Sheet FS-2011-13
- Issues with Canadian and Swiss banks
Benefits
The panel will explore these and other relevant topics:
- The 2012 OVDI: Are its terms sufficiently appealing? What are its penalties? What has changed vs. the 2009 and 2011 disclosure programs?
- The new Form 8938: What should and shouldn't be disclosed on the FATCA report? Where do FATCA and FBAR overlap and diverge? When could FATCA penalties and withholding duties apply?
- Related developments: How could IRS Fact Sheet FS-2011-13 on U.S. citizens and dual residents who failed to file an FBAR create issues? Might complaints from Canadian banks about FBAR and special attention to accounts in Swiss banks create problems?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Kevin Packman
Partner
Holland & Knight
He is attached to his firm's Private Wealth Services Section, where his work emphasizes estate and gift tax planning... | Read More
He is attached to his firm's Private Wealth Services Section, where his work emphasizes estate and gift tax planning for domestic and international clients. He also works with clients on IRS tax controversies, creditor protection planning and probate administration. He has published several articles on FBAR compliance and developments.
CloseMatthew D. Lee
Partner
Blank Rome
He has extensive client advisory experience on FBAR, undeclared foreign bank accounts and the IRS voluntary disclosure... | Read More
He has extensive client advisory experience on FBAR, undeclared foreign bank accounts and the IRS voluntary disclosure program. He is a former Justice Department trial attorney who currently works in white-collar criminal defense and complex civil litigation.
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Igor S. Drabkin
Principal
Holtz Slavett & Drabkin
Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively... | Read More
Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively and in court. Previously in his career, he was a senior IRS trial attorney and a special assistant U.S. attorney on bankruptcy cases involving tax matters.
CloseKelley Miller
Atty
Reed Smith
Ms. Miller’s practice involves complex federal tax controversies, state tax planning and litigation, and tax... | Read More
Ms. Miller’s practice involves complex federal tax controversies, state tax planning and litigation, and tax planning issues involving E-Commerce, cloud computing, and state nexus. She has experience representing clients in civil and criminal tax matters before state tribunals and administrative agencies, state courts, federal courts, and the IRS. Ms. Miller has written and spoken widely on numerous federal and state tax topics for clients representing a broad spectrum of industries.
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