Streamlined Offshore Voluntary Disclosure Program: Avoiding Aggressive Enforcement Regime and Significant Penalties
Leveraging the New OVDP Process for Claiming Non-Willful Failure to File
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide counsel and tax advisors with the tools necessary to navigate the IRS rules governing the extended 2014 Offshore Voluntary Disclosure Program (2014 “OVDP”) to determine whether clients are eligible for the less arduous and punitive streamlined programs.
- History and background of OVDP
- Streamlined disclosure program (SDP)
- U.S. resident
- Non-U.S. resident
- Benefits of streamlined disclosure
- Risks of streamlined disclosure
- Standard of non-willful failure to file
- Required filings
The panel will review these and other key issues:
- What are the new 2014 OVDP requirements?
- What are the new requirements for the streamlined programs? How may a taxpayer take advantage of its benefits?
- What best practices should be used in determining if a taxpayer qualifies for one of the streamlined programs?
- How would a taxpayer demonstrate non-willfulness?
- What conduct constitutes “willful” non-reporting?
- What risks does an applicant in one of the streamlined programs face?
- What are some of the other methods used by taxpayers to become tax compliant with respect to undeclared offshore income and undeclared offshore financial accounts and assets, and what is the viability of these methods? Some of the methods that will be discussed include quiet disclosure, prospective compliance and expatriation
Brager Tax Law Group
Mr. Brager is a California State Bar Certified Tax Specialist, and a former Senior Tax Attorney for the Internal... | Read More
Mr. Brager is a California State Bar Certified Tax Specialist, and a former Senior Tax Attorney for the Internal Revenue Service's Office of Chief Counsel. He is a regular speaker at the UCLA Tax Controversy Institute, and has advised hundreds of clients with unreported offshore accounts. He has been quoted as a tax expert by Business Week, Accounting Today, the Daily Journal, the National Law Journal, The Daily Beast, USA Today, Palm Beach Daily News, Money Laundering, the Los Angeles Daily Journal and Tax Analyst. Dennis has been a guest on ABC Television’s Good Morning America, Fox Business News, TV One Access and KFWB Money 101.Close
Deborah J. Jacobs
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
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.Close
Rubinstein and Rubinstein
Mr. Rubinstein concentrates his practice in domestic and international asset protection, wealth preservation, tax... | Read More
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.Close