FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets
Unraveling Foreign Asset and Income Reporting Obligations, Navigating Available Voluntary Disclosure Programs
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Tuesday, September 9, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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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.
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.
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 who 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.
I. Delinquent information return program
II. IRS disclosure programs
A. U.S. resident
B. Non-U.S. resident
III. Other available options post-OVDP
IV. Current IRS procedures for evaluating voluntary submittals
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 statutes of limitation 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?
