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Willfulness and Voluntary Disclosure


Cost Free
Presentation Length 1.0 hour

Recorded DateMay 29, 2019
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

When a U.S. taxpayer fails to file the FBAR or another informational report, the consequences can be severe, depending in part on the taxpayer’s intent. For example, if the IRS makes a finding of willfulness, the civil penalties can be half of the unreported assets. In this webinar, we will review the different standards of willfulness and nonwillfulness, and we will discuss recent cases involving U.S. taxpayers who failed to disclose their foreign assets. Then we will consider the new voluntary disclosure procedures from the IRS and discuss the process and consequences of disclosure. 

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Ruth helps clients implement comprehensive plans that meet their personal, family, and professional goals. As part of her estate planning practice, Ruth focuses on international planning, including planning for overseas assets, forming offshore asset protection trusts, planning for a spouse who is not a U.S. citizen, and helping U.S. beneficiaries plan to receive gifts and inheritances from abroad. For clients with unreported foreign assets, Ruth coordinates with accountants to help bring the clients into compliance with their FBAR and other reporting requirements. Additionally, Ruth advises trustees and Personal Representatives with the administration of trusts and estates, including local and multinational trusts and estates.

About Our Presenter

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Vacovec, Mayotte & Singer, LLP is a law firm distinguished for its concentration in tax law. Located just outside of Boston, Massachusetts, we provide a full range of tax and related legal services to clients throughout the United States and around the world. Our attorneys are experienced in solving complex tax planning, structuring and compliance issues using creative strategies and determined advocacy on behalf of our clients. Please contact us for more information about our services and our firm.