Voluntary Disclosure of Foreign Assets: Current Challenges for Noncompliant U.S. Taxpayers

Options for Compliance, Avoiding Penalties and Potential Criminal Prosecution

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

Conducted on Thursday, November 14, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE/CPE webinar will provide counsel and tax advisers with guidance on available options for reporting foreign assets of noncompliant U.S. taxpayers. The panel will discuss Foreign Bank Account Report (FBAR) requirements, alternative compliance options after the IRS' termination of the Offshore Voluntary Disclosure Program (OVDP), current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.


The IRS encourages taxpayers to voluntarily disclose foreign assets in compliance with their tax filing and information reporting obligations. Taxpayers must now take advantage of alternative compliance options since the IRS has terminated the OVDP.

The IRS offers other options for noncompliant U.S. taxpayers such as the IRS-Criminal Investigation Voluntary Disclosure Program, Streamlined Filing Compliance Procedures, Delinquent FBAR Submission Procedures, the Delinquent International Information Return Submission Procedures, and the brand-new Relief Procedures for Certain Former Citizens.

However, unlike the OVDP, most of these programs require either "non-willful" conduct and/or "reasonable cause" for failure to timely file and report foreign accounts and assets, including those held through undisclosed foreign entities.

Counsel and tax advisers must be aware of the complex requirements of each disclosure program and decide whether or not a noncompliant U.S. taxpayer should voluntarily disclose foreign assets.

Listen as our panel discusses current options for the voluntary disclosure of foreign assets, the benefits and burdens of alternatives after OVDP, and best practices to determine which program will benefit noncompliant U.S. taxpayers.



  1. Overview of the disclosure requirements of foreign accounts and assets
  2. Identify foreign information noncompliance scenarios
  3. Available alternatives since the end of the OVDP
  4. Best practices for advising the noncompliant U.S. taxpayer
  5. Are quiet disclosures a viable option?
  6. What are the best practices in determining which voluntary disclosure program benefits the client?


The panel will review these and other critical issues:

  • What options are available to clients now that the OVDP has ended?
  • What are the requirements of each IRS voluntary disclosure program?
  • What are the penalties associated with a clients’ failure to participate in these voluntary disclosure programs?


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

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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 program handouts.

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