Offshore Voluntary Disclosure Program (OVDP): A 2017 Outlook
Offshore compliance remains a top priority for the Internal Revenue Service (IRS). Offshore tax avoidance is included in the IRS’ 2017 Dirty Dozen list which highlights the most common tax scams and abuses that the IRS seeks to avert and prosecute. The IRS is also rolling out an OVDP audit campaign which aims to address OVDP or pre-clearance applicants who withdrew from the program voluntarily or were rejected. In case of non-compliance, one should try to resolve it through available offshore programs.
Although coming into compliance is a very challenging task, the consequences of failing to do so are worse than the sanctions for coming clean with the IRS.
In this LIVE Webcast, a panel of distinguished professionals and thought leaders assembled by The Knowledge Group will provide the audience with an overview of the latest developments relating to the IRS Offshore Voluntary Disclosure Program (OVDP). Speakers will also share helpful insights and best compliance practices.
Key topics include:
- OVDP – An Overview
- The OVDP Audit Campaign
- Offshore Tax Avoidance Penalties
- Best Compliance Practices
- 2017 OVDP Outlook
- Background of OVDP and Streamlined Procedures (Kathleen Agbayani)
- Penalties, Statute of Limitations, the Willful Standard (Michel R. Stein)
- Potential Penalties
- Statute of Limitations Considerations
- Willful Standard
- Non-Willful Certification
- Program options and requirements (Jared G. Johnson, EA)
- Delinquent FBAR filing procedures
- Delinquent filing procedures for International
- Non-Program Disposition of Cases (Seth G. Cohen)
- Transitional Relief
- Latest developments in Civil and Criminal Enforcement (Matthew D. Lee)
Who Should Attend:
- Tax Attorneys
- Foreign Investors
- Tax Preparers
- Tax Practitioners
- Tax Professionals
- In-house Counsel
- Private and Public Companies
- Other related/interested Professionals and Organizations
Kathleen Agbayani is of counsel in the North American Tax Practice Group. She joined Baker & McKenzie’s Washington, DC office after serving as an attorney-advisor for the Honorable Robert N. Armen, Jr., at the United States Tax Court. She is a committee member of the North American Tax Practice Group Tax Controversy Steering Committee and the Global Tax Practice Group Voluntary Disclosure Steering Committee. She has spoken at the American Bar Association Section of Taxation and The Tax Executives Institute.
Ms. Agbayani focuses her practice on tax controversy, voluntary disclosures, global wealth management, and transfer pricing. She advises individual and corporate clients on a variety of substantive and procedural matters during examination and administrative audits before the Internal Revenue Service and assists in contesting disputes in court. Ms. Agbayani also provides pro bono advice to many pro bono clients including the American University Washington College of Law Janet R. Spragens Federal Tax Clinic and D.C. Tax Legal Assistance, American Bar Association Military Pro Bono Project.
Kathleen Agbayani is of counsel in the North American Tax Practice Group. She joined Baker & McKenzie’s Washington, DC office …
Matthew D. Lee is a partner in the Philadelphia office of Fox Rothschild LLP. He is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense and federal tax controversies. He has extensive experience in advising clients on issues regarding foreign bank account reporting (FBAR) obligations, the Foreign Account Tax Compliance Act (FATCA), and the Internal Revenue Service’s Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures. He has represented hundreds of U.S. taxpayers with undisclosed offshore bank accounts and assets. Mr. Lee has published numerous articles regarding the IRS voluntary disclosure programs and FBAR and FATCA reporting obligations and speaks frequently on these topics. He has also represented clients in all stages of proceedings before the Internal Revenue Service, including audits, appeals, and collections, and Tax Court and district court litigation. Mr. Lee also has experience in conducting corporate internal investigations and advising clients as to corporate compliance issues involving the Bank Secrecy Act, the USA Patriot Act, FATCA, and anti-money laundering laws and regulations. Mr. Lee has represented corporations and individuals in criminal investigations involving tax, money laundering, health care, securities, public corruption, and fraud offenses, and has significant experience in handling all stages of federal litigation including trials and appeals. Mr. Lee is the author of Foreign Account Tax Compliance Act Answer Book 2016 (Practising Law Institute) and publishes a blog entitled Tax Controversy Sentinel (https://taxcontroversy.foxrothschild.com/).
Matthew D. Lee is a partner in the Philadelphia office of Fox Rothschild LLP. He is a former U.S. Department …
MICHEL R. STEIN is a principal at Hochman, Salkin, Rettig, Toscher & Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For almost 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.
Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.
Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayer’s and their advisors around the world.
Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.
MICHEL R. STEIN is a principal at Hochman, Salkin, Rettig, Toscher & Perez, specializing in tax controversies, as well as …
Seth is an experienced tax compliance litigator who represents clients in U.S. federal, state and local controversies. He has extensive experience in counseling individuals, entities and financial institutions in relation to the U.S. government's focus on undeclared foreign accounts. Currently, he is representing numerous clients worldwide in United State Department of Justice, Internal Revenue Service and state attorneys general in audits/examinations/investigations that have arisen in the normal course, through whistleblowers, and the recent U.S. focus on undeclared offshore accounts. He travels to Asia extensively to service clients and speak on subjects within his areas of expertise. He is an adjunct professor of tax and law at the University of New Haven in Connecticut.
Seth is an experienced tax compliance litigator who represents clients in U.S. federal, state and local controversies. He has extensive …
Jared has more than 11 years of professional experience with Expatriate and Inpatriate taxation. He specializes in international taxation and tax equalization as it specifically relates to individuals. His experience includes both US citizens (and green card holders) working abroad, and individuals from foreign countries working in the United States. Jared has specialized knowledge in various voluntary disclosure programs available to US taxpayer's with undisclosed accounts. Jared is located in our Salt Lake City, UT office.
Jared has more than 11 years of professional experience with Expatriate and Inpatriate taxation. He specializes in international taxation and …
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Method of Presentation:
Experience in taxation
NASBA Field of Study:
Taxes - Technical
NY Category of CLE Credit:
Areas of Professional Practice
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