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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Wednesday, March 16, 2022

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide counsel and tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets and assisting clients with developing programs that provide workable solutions.

Faculty

James Cassidy
International Advisor
Schulman Lobel, LLP

Mr. Cassidy is a Certified Public Accountant (New York) with more than 30 years of experience providing U.S. and international individual tax consulting and compliance services to international assignee executives, high net-worth individuals, investors as well as athletes & entertainers. He gained most of his experience working for some of the largest accounting public accounting firms, such as PwC, and recently with BDO as the U.S. National Tax Technical Leader for expatriate tax services. He spent several years living in Mexico City and Toronto, assisting clients with local and U.S. tax advice.

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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 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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Parag P. Patel
Attorney
Patel Law Offices

Mr. Patel’s practice concentrates on tax, international tax planning, estate planning, and elder law. His focus is on all tax matters including international tax law, foreign bank account disclosures, tax audit defense, and tax appeals. He has advocated over one hundred voluntary tax disclosures for assets before the US Internal Revenue Service. He is a frequent speaker and writer on legal issues affecting tax, foreign account planning, and estate planning.

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Description

The IRS has continually reaffirmed its commitment to cracking down on U.S. taxpayers failing to disclose reportable foreign assets. The IRS is intensifying audits for foreign disclosures, and tax advisers need to act quickly to take advantage of the benefits that may apply to their situations.

Tax counsel and advisers must prepare now to assist clients in utilizing any remaining available programs and development methods to ensure reporting compliance. Clients will benefit from substantially reduced or no penalties for failure to report offshore accounts. However, counsel must be aware of the risks in each available program, as the sanctions imposed on taxpayers that willfully fail to disclose are incredibly harsh.

Counsel must first evaluate whether the disclosure program will help a taxpayer avoid increased IRS penalties. If so, counsel must guide the client in meeting the particular requirements of the program. Further changes to the current landscape of offshore reporting may occur at any time, so tax counsel should make client taxpayers aware of the potential tax and penalty savings from disclosure.

Listen as our experienced panel reviews the benefits and burdens of the revised programs and provides best practices in determining whether the programs will benefit clients in the resolution of undisclosed offshore accounts.

Outline

  1. Delinquent information return program
  2. IRS disclosure programs
    • U.S. resident
    • Non-U.S. resident
  3. Other available options post-OVDP
  4. Current IRS procedures for evaluating voluntary submittals

Benefits

The panel will review these and other priority issues:

  • Explaining to your client the value of not waiting until the IRS shows up on their doorstep to fix their offshore filing issues
  • What is the statute of limitations on IRS assessment when taxpayers fail to meet their obligations to report their offshore assets or accounts and how does this statute of limitations compare with other statute of limitations found in the Internal Revenue Code?
  • What are the requirements for the delinquent international information return submission procedures and the delinquent FBAR submission procedures? When does a taxpayer qualify for these procedures?
  • How should tax advisers best navigate the disclosure program requirements?

NASBA Details

Learning Objectives

Upon completing this seminar, you will be able to:

  • Recognize the risks and potential benefits of the revised voluntary disclosure programs
  • Identify situations in which the taxpayer's failure to disclose may be classified as "willful" by the IRS
  • Decide which disclosure program is a better option for a taxpayer with delinquent information reporting

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other attorneys or accountants. Specific knowledge and understanding of foreign asset information reporting requirements, particularly FATCA and FBAR/FinCen 114; familiarity with IRS audit procedures in examining foreign tax reporting, familiarity with voluntary disclosure programs.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).