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.
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.
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.