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

Unraveling Foreign Asset and Income Reporting Obligations, Navigating Available Voluntary Disclosure Programs

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

Conducted on Wednesday, February 6, 2019

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide counsel and tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets, as well as assisting clients with developing programs that provide workable solutions.


The IRS has modified or eliminated programs allowing for late reporting of undisclosed offshore assets. 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 apply to their situations.

With the termination of the OVDP, tax counsel and advisers must prepare now to assist clients on utilizing any remaining available programs and development methods to ensure reporting compliance. 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 available programs, as the sanctions imposed on taxpayers that willfully fail to disclose are incredibly 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 particular requirements of the program. Further changes to the current landscape of offshore reporting may occur at any time, so tax counsel should make client taxpayers aware of the potential tax and penalty savings from disclosure.

Listen as our experienced panel reviews the benefits and burdens of the revised programs and provides best practices in determining whether the 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. Other available options Post-OVDP
  4. Current IRS procedures for evaluating voluntary submittals


The panel will review these and other priority 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 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 other available programs benefit taxpayers?
  • What are the best practices to implement in determining how these voluntary disclosure programs can work for particular clients?
  • How should tax advisers best navigate the disclosure program requirements?


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

Certified Tax Specialist
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

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

Gallet Dreyer & Berkey

Mr. Rubinstein's practice focuses on domestic and international asset protection, wealth preservation, estate...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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