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

Options for Compliance, Avoiding Penalties and Potential Criminal Prosecution

A live 90-minute premium CLE/CPE video webinar with interactive Q&A


Tuesday, November 23, 2021

1:00pm-2:30pm EST, 10:00am-11:30am PST

Early Registration Discount Deadline, Friday, October 29, 2021

or call 1-800-926-7926

This CLE/CPE course 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.

Description

The IRS encourages taxpayers to voluntarily disclose foreign assets in compliance with their tax filing and information reporting obligations. Taxpayers are limited to 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, the Streamlined Filing Compliance Procedures (Foreign and Domestic), the 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.

READ MORE

Outline

  1. Overview of the disclosure requirements of foreign accounts and assets
  2. What is willful blindness?
  3. A Deep Dive into the IRS’ Non-Willful Disclosure Programs
  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?

Benefits

The panel will review these and other critical issues:

  • What options are available to clients?
  • What are the requirements of each IRS’ voluntary disclosure program?
  • What are the penalties associated with a client’s failure to participate in these voluntary disclosure programs?

Faculty

Jacobs, Deborah J.
Deborah J. Jacobs

Owner
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

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

Attend on November 23

Early Discount (through 10/29/21)

See NASBA details.

Cannot Attend November 23?

Early Discount (through 10/29/21)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video

Download