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

Conducted on Wednesday, March 21, 2012
Recorded event now available

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.


Advisors and taxpayers affected by the revised Report of Foreign Bank and Financial Accounts (FBAR) have new developments to analyze, starting with the latest IRS offshore voluntary disclosure initiative (OVDI). With maximum penalties increased and no current expiration date, terms of the deal must be mastered.

Meanwhile, calendar-year taxpayers should prepare for first filings of Form 8938, a.k.a. the Foreign Account Tax Compliance Act (FATCA) information report on funds in overseas accounts and other foreign financial assets. Issuance of Form 8938 and Sect. 6038D administrative rules (T.D. 9567) give much to consider.

Given those developments, new IRS guidance for U.S. citizens and dual residents abroad, controversy over FBAR's applicability to Canadian and Swiss banks, and the cost of potential FBAR-related civil penalties, tax professionals must familiarize themselves with the OVDI, FATCA rules and other recent events.

Listen as our panel of seasoned tax advisors explores pros and cons of the voluntary disclosure offer, FATCA report requirements and impact of related developments.


  1. The 2012 IRS OVDI
    1. Eligibility
    2. Potential penalties
    3. Pros and cons
    4. When expiration date will be set
  2. FATCA foreign account information reporting
    1. T.D. 9567 and Sect. 6038D rules
    2. Accounts and taxpayers covered
    3. Form 6038 and instructions
    4. Potential penalties
    5. Withholding rules
  3. Other recent developments
    1. IRS Fact Sheet FS-2011-13
    2. Issues with Canadian and Swiss banks


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?

Upon completing this seminar, you will have a firm grasp of the implications of the latest FBAR-related disclosure offer, FATCA reporting obligations, and other latest developments pertaining to foreign account compliance.


Kevin Packman, Partner
Holland & Knight, Miami, Fla.

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.

Matthew D. Lee, Partner
Blank Rome, Philadelphia

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.

Igor S. Drabkin, Principal
Holtz Slavett & Drabkin, Beverly Hills, Calif.

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.

Kelley Miller, Atty
Reed Smith, Philadelphia

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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