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.
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.