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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 video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
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Conducted on Tuesday, December 5, 2023

Recorded event now available

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, 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 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 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. 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?


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?


Glaser, Guy
Guy Glaser

Brager Tax Law

Mr. Glaser has over 30 years of tax experience with the IRS. He spent the first twenty years as a Senior Trial Attorney...  |  Read More

Vincent, Meredith
Meredith Vincent

Tax Attorney
Brager Tax Law Group

Ms. Vincent obtained her BBA in Accounting, summa cum laude, from National University in 1995. She was a Tax Preparer...  |  Read More

Access Anytime, Anywhere

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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