This session covered the IRS’s enforcement efforts in the area of unreported foreign assets and the consequences for those taxpayers who maintain unreported foreign accounts. Also covered were 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 discussed the key issue of whether a taxpayer’s noncompliance was willful or merely negligent and why that matters.
Learning Objectives Included
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.