About the Course
Introduction
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.
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.
Presented By
Mr. Keim is a Certified Tax Law Specialist, Best Lawyers® honoree, CPA, and senior partner in the firm. He combines litigation experience and a strong understanding of accounting and business concepts in tax matters to represent clients in defense of taxing authorities and provide strategic tax advice before a dispute arises. Mr. Keim joined Frazer Ryan after serving as a senior trial attorney with the Internal Revenue Service. At the IRS, he received the Chief Counsel National Award for Superior Achievement in Outstanding Litigation, and he was frequently recognized for his service as a trial attorney.
Ms. Schenck joined Caplin & Drysdale in 2025 after two decades of public service. Most recently she served as the National Fraud Counsel and Senior Level Counsel (Offshore) in the Office of Chief Counsel at the IRS. Ms. Schenck assists corporations, individuals, families, trust companies, and tax professionals with criminal and civil tax enforcement and compliance matters. Specifically, she helps clients navigate compliance issues even before IRS involvement, as well as advising clients on civil examinations, summons and subpoena matters, tax and penalty issues, sensitive audits and fraud cases, criminal tax investigations, and related litigation. Ms. Schenck was elected as a Fellow of the American College of Tax Counsel (ACTC) for her extraordinary professional achievements and her dedication to improving the practice of tax law.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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CPE credit is not available on recordings.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Tuesday, December 1, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Overview of disclosure requirements of foreign accounts and assets
II. What is willful blindness?
III. A deep dive into the IRS' non-willful disclosure programs
IV. Best practices for advising the noncompliant U.S. taxpayer
V. Are quiet disclosures a viable option?
VI. What are the best practices in determining which voluntary disclosure program benefits the client?
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?
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
- 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.
BARBRI, 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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
Related Courses
Voluntary Disclosure of Foreign Assets: Current Challenges for Noncompliant U.S. Taxpayers
Tuesday, December 1, 2026
1:00 PM ET/10:00 AM PT
