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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, December 5, 2023

  • 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, current challenges facing noncompliant taxpayers, and tactics to avoid penalties and potential criminal prosecution.

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 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 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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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 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: Prerequisites: 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).