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 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.
Outline
- Overview of the disclosure requirements of foreign accounts and assets
- What is willful blindness?
- A deep dive into the IRS' non-willful disclosure programs
- Best practices for advising the noncompliant U.S. taxpayer
- Are quiet disclosures a viable option?
- 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
Guy Glaser
Attorney
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
Mr. Glaser has over 30 years of tax experience with the IRS. He spent the first twenty years as a Senior Trial Attorney for the Service’s Office of Chief Counsel’s Small Business and Self-Employed (SBSE) Division. For the next 10 years, he served as the Laguna Niguel Associate Area Counsel for the IRS Office of Chief Counsel’s Large Business and International (LB&I) Division. He also worked a 6-month stint as a Special Assistant United States Attorney for the Office of the United States Attorney, Central District of California, Tax Division in Los Angeles. As a Senior Trial Attorney for the IRS Office of Chief Counsel’s Small Business and Self-Employed Division, Mr. Glaser was responsible for providing legal advice to the IRS on tax audits and collection matters. He also assisted in implementing the IRS’s Offshore Compliance Initiative and the Offshore Credit Card Program. He served as one of the initial eleven nationwide IRS Office of Chief Counsel FBAR Coordinators
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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
Ms. Vincent obtained her BBA in Accounting, summa cum laude, from National University in 1995. She was a Tax Preparer before joining Brager Tax Law Group in 2009 as a paralegal. Ms. Vincent later went on to become an Enrolled Agent, practicing before the IRS and the state taxing agencies. She completed her Law Degree from Glendale University College of Law in Los Angeles County and received her JD with high honors. Ms. Vincent's main focus at BTLG is assisting our clients with offshore / foreign reporting requirements with the IRS as well as State taxing authorities.
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