Report of Foreign Bank and Financial Accounts: Preparing for 2011 Filings
Evaluating the Final FBAR Regs, Second Voluntary Compliance Offer and Other Developments
June 30 deadline rapidly approaching
Recording of a 110-minute CPE webinar with Q&A
This teleconference will prepare advisors and taxpayers to comply with the rapidly approaching 2011 deadline for filing the Foreign Bank and Financial Accounts Report (FBAR) and the 6038D return. The panel will review lessons from filing the revised form and evaluate the IRS 2011 Offshore Voluntary Disclosure Program.
Outline
- Key aspects of the updated Form TD F 90.22-1 (FBAR), issued October 2008
- Requirement for persons in or doing business in the U.S. to file FBAR
- “Doing business” standard delayed
- IRS guidance on that issue forthcoming
- Expanded list of domestic corporation officers and employees who are exempt from filing requirement
- Expanded definition of reportable financial accounts
- Expanded definition of “financial interest” through ownership in corporations, partnerships or trusts
- Broadened standards for who holds signatory authority over foreign accounts
- Requirement for persons in or doing business in the U.S. to file FBAR
- Material terms of the finalized FBAR regs from Treasury FinCEN
- Resolve uncertainty over “U.S. person” definition
- Specify what financial accounts must be reported
- Expand signature authority over accounts
- Other changes
- The 2011 voluntary disclosure program
- Terms
- Advantages and disadvantages
- Experiences with previous FBAR VDAs
- Recent guidance on FBAR
- Williams v. U.S. decision on duty to pay FBAR non-filing penalty
- Compliance experiences from June 2010 filings of new FBAR
- What will be required in FATCA Sect. 6038D information return
Benefits
The panel will get you ready for these and other problematic aspects of FBAR:
- The finalized FinCEN regs: What you need to know about who the definition of "U.S. person" covers, which filers and accounts are exempted, etc.
- The 2011 voluntary disclosure program: The pros and cons.
- General terms of FBAR: Which U.S. and foreign taxpayers owe information about interests in foreign accounts and funds to the government by June 30, 2011.
- Court rulings and other guidance: What can be gleaned from decisions such as Williams v. U.S. on FBAR non-filing penalties.
- Anticipating the Sect. 6038D return: Why many FBAR filers will complete this form as well, and what to expect.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Dennis Brager
Founder
Brager Tax Law Group
His firm specializes in tax controversy work. He previously worked for six years as a senior tax attorney with the IRS... | Read More
His firm specializes in tax controversy work. He previously worked for six years as a senior tax attorney with the IRS Office of District Counsel.
CloseBrent Lipschultz
Partner
EisnerAmper
Mr. Lipschultz has 15 years of experience with international wealth advisor practice matters and writes and speaks... | Read More
Mr. Lipschultz has 15 years of experience with international wealth advisor practice matters and writes and speaks frequently on related topics such as FBAR. He formerly was a member in the Global Wealth Service Practice at a Big Four firm.
CloseKevin 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.
CloseSteven Toscher
Principal
Hochman Salkin Rettig Toscher & Perez
He has a broad-based tax practice covering federal and state income taxes and estate, employment, excise, sales and... | Read More
He has a broad-based tax practice covering federal and state income taxes and estate, employment, excise, sales and property tax matters. He previously headed the West Coast tax litigation practice for another firm and also worked as a trial attorney in the U.S. Justice Department's Tax Division.
Close