HomeWebcastForeign Bank Account Reporting and Enforcement Update:The Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative and the New FBAR Regulations
Foreign Bank Account Reporting and Enforcement CLE

Foreign Bank Account Reporting and Enforcement Update:The Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative and the New FBAR Regulations

Live Webcast Date: Thursday, June 16, 2011 from 3:00 pm to 5:00 pm (ET)
Legal (CLE)Recording

Foreign Bank Account Reporting and Enforcement

Join us for this Knowledge Group Foreign Bank Account Reporting and Enforcement Webinar. All U.S. taxpayers are required to file an annual reporting form, called a Report of Foreign Bank and Financial Accounts (or FBAR), stating whether they have a financial interest in any bank accounts maintained in foreign countries. The failure to file this form annually is a felony and can also subject non-filers to substantial civil penalties.Both the U.S. Justice Department and Internal Revenue Service have announced that foreign bank account reporting and compliance is a top enforcement priority. In 2009, the Justice Department entered into a Deferred Prosecution Agreement with UBS AG, Switzerland’s largest bank, in which UBS agreed that it had assisted thousands of U.S. taxpayers in committing tax evasion by maintaining secret bank accounts in Switzerland for decades. Since that time, over twenty criminal prosecutions have been filed against UBS accountholders, bankers, and investment advisors. Also in 2009, the IRS conducted a highly successful amnesty program for holders of undeclared foreign bank accounts. During the term of that program, over 15,000 individuals came forward and admitted that they had secret bank accounts in Switzerland and other foreign jurisdictions.In February 2011, the Internal Revenue Service unveiled its 2011 Offshore Voluntary Disclosure Initiative, a long-awaited second amnesty program designed to encourage U.S. taxpayers with undisclosed foreign bank accounts to come into compliance with U.S. tax laws and avoid possible criminal prosecution. Shortly thereafter, the Treasury Department announced new regulations governing foreign bank account reporting which are effective for FBARs due to be filed by June 30, 2011. These new regulations make substantial changes to the foreign bank account reporting requirements and are effective immediately.This program would provide an update on foreign bank account reporting and enforcement, including the new IRS amnesty program, the new FBAR regulations, and the U.S. government’s enforcement efforts in this area

Agenda

SEGMENT 1:
Erika Litvak, Shareholder, 
Greenberg Traurig

  • FBAR Reporting Foundation
    General Principle
    • Who must file?
    • What needs to be reported?
    • When is the filing due?
    • Are there exceptions?
    • What are the penalties for failure to file?

SEGMENT 2:
Matthew D. Lee, Partner, 
Blank Rome LLP

  • IRS/DOJ Enforcement Efforts Regarding FBAR Reporting and Offshore Tax Evasion
  • Bradley Birkenfeld – UBS whistleblower
  • UBS Deferred Prosecution Agreement (Feb. 2009)
  • Turnover of UBS accountholder information by UBS and Switzerland
  • Data mining by U.S. for leads
  • Criminal prosecutions of UBS accountholders and Swiss bankers, advisors, and promoters
  • Recent prosecutions of accountholders and bankers at Credit Suisse and HSBC (2011)
  • Service of IRS “John Doe” summons on HSBC regarding accounts in India (2011)
  • Anticipated future enforcement efforts by U.S. government

SEGMENT 3:
Terence Coppinger, Partner, 
Deloitte Tax LLP

  • Primer on the requirements of the 2011 OVD
  • Integration of the 2011 fbar requirements and the OVD program.
  • Taxpayers experiences with previous ovd

Who Should Attend

  • Tax Attorneys
  • Trust and Estate Attorneys
  • CPAs/accountants
  • Chief Financial Officers
  • Corporate Tax Professionals and Financial Executives
  • Financial Advisors and Money Managers

Foreign Bank Account Reporting and Enforcement

SEGMENT 1:
Erika Litvak, Shareholder, 
Greenberg Traurig

  • FBAR Reporting Foundation
    General Principle
    • Who must file?
    • What needs to be reported?
    • When is the filing due?
    • Are there exceptions?
    • What are the penalties for failure to file?

SEGMENT 2:
Matthew D. Lee, Partner, 
Blank Rome LLP

  • IRS/DOJ Enforcement Efforts Regarding FBAR Reporting and Offshore Tax Evasion
  • Bradley Birkenfeld – UBS whistleblower
  • UBS Deferred Prosecution Agreement (Feb. 2009)
  • Turnover of UBS accountholder information by UBS and Switzerland
  • Data mining by U.S. for leads
  • Criminal prosecutions of UBS accountholders and Swiss bankers, advisors, and promoters
  • Recent prosecutions of accountholders and bankers at Credit Suisse and HSBC (2011)
  • Service of IRS “John Doe” summons on HSBC regarding accounts in India (2011)
  • Anticipated future enforcement efforts by U.S. government

SEGMENT 3:
Terence Coppinger, Partner, 
Deloitte Tax LLP

  • Primer on the requirements of the 2011 OVD
  • Integration of the 2011 fbar requirements and the OVD program.
  • Taxpayers experiences with previous ovd

Foreign Bank Account Reporting and Enforcement

Foreign Bank Account Reporting and Enforcement

Erika LitvakShareholderGreenberg Traurig

Erika concentrates her practice on taxation, with special emphasis on international taxation. Erika assists individuals with off-shore income tax and estate planning, expatriation, pre-immigration planning, structuring investments in the United States, etc. Erika also assists U.S. and foreign entities in cross-border transactions, merger and acquisitions, investments of U.S. entities abroad and investments of foreign entities in the United States, establishment of operations in the United States and abroad as well as with reporting and compliance issues in addition to any other aspect related to international taxation.

  • Areas of Concentration
  • Pre-immigration planning
  • Expatriation
  • Off-shore income tax and estate planning
  • Investment in the United States
  • Acquisition, maintenance and sale of U.S. real estate by foreigners
  • Reporting and compliance
  • Cross-border transactions
  • Mergers and acquisitions
  • U.S. companies investing or doing business abroad
  • Starting or restructuring operations in the United States
  • Foreign Account Tax Compliance Act (FATCA)
Foreign Bank Account Reporting and Enforcement

Matthew D. LeePartnerBlank Rome LLP

Matthew D. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on white collar criminal defense and federal tax controversies. He has extensive experience in advising clients on foreign bank account reporting obligations and voluntary disclosures of offshore accounts, and has published numerous articles on these topics. He also has represented clients in all stages of proceedings before the IRS, including audits, appeals, and collections, and Tax Court litigation. Matthew has experience in conducting corporate internal investigations and advising clients on corporate compliance issues involving the Bank Secrecy Act, the USA Patriot Act, and anti-money laundering laws. He has represented corporations and individuals in criminal investigations involving tax, money laundering, health care, securities, public corruption, and fraud offenses.

Foreign Bank Account Reporting and Enforcement

Terence CoppingerDirectorDeloitte Tax LLP

Terence Coppinger is a Director with Deloitte Tax LLP in their New York City office. He advises the Firm’s clients in the areas of tax information reporting and IRS practice and procedure. He is responsible for provided consulting services on withholding obligations, qualified intermediaries and matters involving domestic and nonresident alien Federal withholding and reporting. Terence has represented some of his Firm’s largest clients before the IRS and he oversees Deloitte’s Northeast Non resident Alien and domestic information reporting compliance practice.Prior to joining Deloitte, Mr. Coppinger worked for the Internal Revenue Service as a Revenue Officer and Revenue Agent. Mr. Coppinger has co-authored numerous articles in such widely circulated publications as The Journal of Bank Taxation, Practical Tax Strategies and The Tax Adviser. He is also an adjunct associate professor at St. John’s University Tobin College of Business where he teaches graduate courses in IRS Practice and Procedure, Federal Tax Research and Tax Research and Writing. He is a Certified Public Accountant, a member of the AICPA and the New York State Society of Certified Public Accountants. He holds a BS in Finance and MBA with a specialization in Public Accounting from St. John’s University and a MS in Taxation from Pace University.


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Foreign Bank Account Reporting and Enforcement

Course Level:
   Intermediate

Advance Preparation:
   Print and review course materials

Method Of Presentation:
   On-demand Webcast

Prerequisite:
   NONE

Course Code:
   114142

Total Credits:
    2.0 CLE

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About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

Greenberg Traurig is an international law firm with 1800 attorneys and governmental affairs professionals. Greenberg Traurig offers clients local resources and capabilities in 32 financial, business and government centers, including more U.S. locations than any other Top 10 law firm on The National Law Journal’s 2010 NLJ 250.Greenberg Traurig provides integrated legal services for clients worldwide. We offer a multidisciplinary team, including senior lawyers who have been the chief legal officers at major multinational companies and have spent years solving real-world problems in the business, political and legal arenas. We build teams around client needs, ensuring lean staffing, front-end planning and flexible billing, where appropriate. Our experience in multiple practice areas and our network of contacts in the United States and abroad position us to help clients achieve their objectives.Greenberg Traurig serves clients from locations in Albany, NY; Amsterdam, The Netherlands; Atlanta, GA; Austin, TX; Boston, MA; Chicago, IL; Dallas, TX; Denver, CO; Fort Lauderdale, FL; Houston, TX; Las Vegas, NV; London, England ( Operates as Greenberg Traurig Maher LLP ), Los Angeles, CA; Miami, FL; Morristown, NJ; New York, NY; Orange County, CA; Orlando, FL; Palm Beach County, FL; Philadelphia, PA; Phoenix, AZ; Sacramento, CA; San Francisco, CA; Shanghai, China; Silicon Valley, CA; Tallahassee, FL; Tampa, FL; Tysons Corner, VA; Washington, D.C.; White Plains, NY; and Wilmington, DE. Additionally, the firm has established a strategic alliance with the independent law firm Studio Santa Maria in Milan and Rome.

Website: https://www.gtlaw.com/

Blank Rome is a full-service, multi-disciplinary law firm with offices in California, Delaware, Florida, Houston, New Jersey, New York, Ohio, Philadelphia, Washington, Hong Kong, and later this spring, Shanghai. It is one of America’s fastest growing law firms with close to 550 support staff and over 500 attorneys engaged in the practice of law across many disciplines providing exceptional service to clients for more than 60 years.

Website: https://www.blankrome.com/

In the United States, Deloitte LLP and its subsidiaries have 45,000 professionals with a single focus: serving clients and helping them solve their toughest problems. Deloitte LLP work in four key business areas — audit, financial advisory, tax and consulting — but the real strength comes from combining the talents of those groups to address clients’ needs. Fortune and Business Week consistently rank Deloitte LLP among the best places to work. When the best people tackle the most compelling challenges, everyone wins.

Website: https://www.deloitte.com/

Erika concentrates her practice on taxation, with special emphasis on international taxation. Erika assists individuals with off-shore income tax and estate planning, expatriation, pre-immigration planning, structuring investments in the United States, etc. Erika also assists U.S. and foreign entities in cross-border transactions, merger and acquisitions, investments of U.S. entities abroad and investments of foreign entities in the United States, establishment of operations in the United States and abroad as well as with reporting and compliance issues in addition to any other aspect related to international taxation.

  • Areas of Concentration
  • Pre-immigration planning
  • Expatriation
  • Off-shore income tax and estate planning
  • Investment in the United States
  • Acquisition, maintenance and sale of U.S. real estate by foreigners
  • Reporting and compliance
  • Cross-border transactions
  • Mergers and acquisitions
  • U.S. companies investing or doing business abroad
  • Starting or restructuring operations in the United States
  • Foreign Account Tax Compliance Act (FATCA)

Matthew D. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on white collar criminal defense and federal tax controversies. He has extensive experience in advising clients on foreign bank account reporting obligations and voluntary disclosures of offshore accounts, and has published numerous articles on these topics. He also has represented clients in all stages of proceedings before the IRS, including audits, appeals, and collections, and Tax Court litigation. Matthew has experience in conducting corporate internal investigations and advising clients on corporate compliance issues involving the Bank Secrecy Act, the USA Patriot Act, and anti-money laundering laws. He has represented corporations and individuals in criminal investigations involving tax, money laundering, health care, securities, public corruption, and fraud offenses.

Terence Coppinger is a Director with Deloitte Tax LLP in their New York City office. He advises the Firm’s clients in the areas of tax information reporting and IRS practice and procedure. He is responsible for provided consulting services on withholding obligations, qualified intermediaries and matters involving domestic and nonresident alien Federal withholding and reporting. Terence has represented some of his Firm’s largest clients before the IRS and he oversees Deloitte’s Northeast Non resident Alien and domestic information reporting compliance practice.Prior to joining Deloitte, Mr. Coppinger worked for the Internal Revenue Service as a Revenue Officer and Revenue Agent. Mr. Coppinger has co-authored numerous articles in such widely circulated publications as The Journal of Bank Taxation, Practical Tax Strategies and The Tax Adviser. He is also an adjunct associate professor at St. John’s University Tobin College of Business where he teaches graduate courses in IRS Practice and Procedure, Federal Tax Research and Tax Research and Writing. He is a Certified Public Accountant, a member of the AICPA and the New York State Society of Certified Public Accountants. He holds a BS in Finance and MBA with a specialization in Public Accounting from St. John’s University and a MS in Taxation from Pace University.

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