Foreign Asset Disclosure Noncompliance and Penalty Abatement After OVDP Closing
Remaining IRS Voluntary Disclosure Initiatives, Challenging Finding of Willful Failure, Requesting Penalty Relief
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a useful and practical guide to navigating the IRS disclosure and penalty abatement process for foreign information reporting noncompliance after the closing of the Overseas Voluntary Disclosure Program (OVDP). The panel will discuss the remaining avenues for remedying delinquent or incorrect foreign asset disclosure filings and detail ways to reduce penalties after OVDP.
Outline
- OVDP- A brief history
- Criminal Penalties
- Remaining structured procedures
- Streamlined filing compliance procedures
- Streamlined Domestic Offshore Procedure for U.S. residents
- Streamlined Foreign Offshore Procedure for non-U.S. residents
- Delinquent FBAR Submission Procedure
- Delinquent International Return Submission Procedure
- Noisy Disclosures vs. Quiet Disclosures
- Penalty structures outside of formal IRS programs and procedures
- Reasonable cause abatement standards
- Willfulness and Reckless Disregard. Will you know it when you see it?
- Going to Court
- Tips for avoiding tax preparer malpractice or IRC 6694 penalties
Benefits
The panel will review these and other priority issues:
- What are the penalty structures for non-willful and willful failure to file?
- What are the standards for “reasonable cause” abatement?
- What standards are used by the courts and the IRS to determine willfulness?
- How the remaining IRS streamlined procedures can be used to mitigate various penalties?
Faculty
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
Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and tax controversy matters. Before founding the Brager Tax Law Group, a Los Angeles-based tax litigation and tax controversy law firm, he was a senior trial attorney for the Internal Revenue Service’s Office of Chief Counsel. Since 2008 he has represented several hundred clients with offshore accounts. He also represents clients on a variety of issues, including criminal and civil tax fraud, tax audit and appeals, payroll and sales tax problems, tax preparer penalties, innocent spouse defenses, offers in compromise, installment payment agreements, Office of Professional Responsibility (“OPR”) defenses and more.
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Robert V. Hanson, Esq.
Tax Manager
Moore Doeren Mayhew
Mr. Hanson’s practice focuses on individuals and organizations with offshore assets and international tax... | Read More
Mr. Hanson’s practice focuses on individuals and organizations with offshore assets and international tax exposure. He represents clients during examinations, administrative appeals of FBAR and international information reporting form penalties, and offshore voluntary disclosures, as well as providing advice to taxpayers with foreign businesses regarding possible U.S. tax exposure. Prior to joining the firm, Mr. Hanson worked with low income taxpayers at the University of Connecticut School of Law.
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Anthony E. Parent
Founding Partner
Parent & Parent
Mr. Parent is the founding partner of his firm, and has a tremendous amount of success in opt-out audits and FBAR... | Read More
Mr. Parent is the founding partner of his firm, and has a tremendous amount of success in opt-out audits and FBAR appeals. He represents U.S. taxpayers around the globe. He give numerous trainings on video and podcasts. He is a published writer, including The IRSMedic blog. He is quoted on tax issues in the national broadcast media. In 2012, he co-authored a business bestseller compilation Protect & Defend. He is currently finishing his first solo effort: IRS Confidential.
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