Megan L. Brackney presents "Coming into Compliance Representing Taxpayers with Unreported Foreign Assts," NYU 7th Annual Tax Controversy Institute, NYC, NY

Taxpayers continue to use the Offshore Voluntary Disclosure Program and related programs to report previously undeclared foreign assets. The IRS changed the OVDP in July 2015 to allow certain taxpayers to make streamlined submissions and to pay reduced penalties or to avoid penalties altogether. However, streamlined submissions are available only to taxpayers who can certify that their past non-compliance was not willful. What does willfulness mean in this context and who is eligible to make a streamlined submission? This program discusses which taxpayers must use the OVDP and which taxpayers should consider a streamlined submission, as well as the issues involved in making streamlined submissions.

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