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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

    Tuesday, November 23, 2021

  • 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 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.

Faculty

Dennis N. Brager
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 tax controversy matters. Before founding the Brager Tax Law Group, a Los Angeles-based tax litigation and tax controversy law firm, he was a senior trial attorney for the Internal Revenue Service’s Office of Chief Counsel. Since 2008 he has represented several hundred clients with offshore accounts. He also represents clients on a variety of issues, including criminal and civil tax fraud, tax audit and appeals, payroll and sales tax problems, tax preparer penalties, innocent spouse defenses, offers in compromise, installment payment agreements, Office of Professional Responsibility (“OPR”) defenses and more.

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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 transactions, tax treaty planning, foreign tax credit planning, repatriation and deferral planning, and international tax compliance. Her clients are individuals, foreign companies and entities, and individuals or financial institutions doing business or residing in the United States, U.S. companies and entities, and financial institutions doing business or residing abroad.

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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.

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?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify areas of noncompliance by taxpayers holding foreign accounts and assets
  • Determine which compliance options are available to taxpayers after the end of the OVDP
  • Discern the applicable penalties associated with a taxpayer's failure to file and report foreign accounts and assets

  • 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; supervisory authority over other preparers/accountants. Specific knowledge and understanding of FBAR triggers and familiarity with failure to disclose foreign accounts and assets penalties and IRS 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).