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UNREPORTED FOREIGN ASSETS: IRS ENFORCEMENT, CONSEQUENCES & PATHWAY TO COMPLIANCE

Cost Free
Presentation Length 1.5 hours

Recorded DateJune 15, 2018
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

This session will cover the IRS’s enforcement efforts in the area of unreported foreign assets and the consequences for those taxpayers who maintain unreported foreign accounts. We will also cover the different pathways to compliance for a taxpayer that has previously not complied with his or her foreign asset reporting obligations, such as the IRS’s Offshore Voluntary Disclosure Program. Finally, this session will discuss the key issue of whether a taxpayer’s noncompliance was willful or merely negligent and why that matters.
 

Learning Objectives

  • A Review of the IRS’s Offshore Voluntary Disclosure Program and the IRS’s general Voluntary Disclosure Policy.

  • When should a taxpayer make a voluntary disclosure?

  • The risks and benefits of the IRS’s Streamlined Compliance Procedures for taxpayers with unreported foreign assets.

PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Michael Sardar has extensive experience in a wide range of tax controversy and white-collar criminal defense matters. Mr. Sardar represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.

About Our Presenter

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Kostelanetz & Fink, LLP enjoys an unparalleled national reputation for representing clients in sensitive and high-stakes negotiations and controversies with government agencies, including tax audits and trials, regulatory investigations, white collar criminal defense and complex litigation. Our attorneys are dedicated to providing the finest legal services in all phases of representation, from factual development, through an audit or investigation, to trial or negotiated resolution. We also have an active practice providing tax planning advice, estate planning and representation in government procurement and government contracting.