Recent IRS OVDP Developments: How Will It Impact the 2018 Landscape
The tolerance of Internal Revenue Service (IRS) for potential non-compliant taxpayers is waning. Recently, the IRS announced that the Offshore Voluntary Disclosure Program (OVDP) is set to end on September 1, 2018. The soon-to-expire OVDP provides an avenue for U.S. taxpayers, who failed to satisfy their disclosure and reporting obligations, to mitigate the consequences of nondisclosure. With the streamlined compliance’s impending termination, taxpayers who have noncompliance issues with respect to their foreign income, should immediately take advantage of the program while it’s still in place.
In this LIVE Webcast, a panel of distinguished professionals and thought leaders brought together by The Knowledge Group will help taxpayers with foreign income and their counsel, understand the important aspects of this significant topic. They will provide an in-depth discussion of recent IRS OVDP developments, particularly the impact of OVDP’s imminent shutdown. Speakers will also offer best compliance practices and strategies to avoid common pitfalls and risk issues.
Key topics include:
- Recent IRS OVDP Developments
- Implications of the OVDP’s Termination
- To Enter OVDP or Not?
- Immediate Actions to Take
- 2019 Outlook
Baker & McKenzie LLP
McDermott Will & Emery LLP
- History of OVDP (Kathleen)
- End of current OVDP (Laura)
- Where there be another program? (Kathleen/Laura)
- What do you do after the current OVDP ends? (Kathleen/Laura)
- Enforcement priorities (5471/3520) (Laura)
- Penalties (Kathleen/Laura)
- Statute of limitations (Kathleen/Laura)
- FBAR litigation (Laura)
Who Should Attend:
- 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 …
Laura L. Gavioli, PC, defends individuals and corporations in white-collar prosecutions, civil tax cases, US Internal Revenue Service (IRS) controversies and complex financial litigation. Laura represents numerous taxpayers who are facing civil and criminal issues regarding their reporting of offshore financial accounts and other assets. Laura has also represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the United States, and she regularly advises clients regarding the IRS Whistleblower Program. Her experience includes significant taxpayer victories in civil tax cases in US Tax Court and federal district courts, eliminating IRS penalties due to clients’ good faith and reasonable cause. Laura has also litigated numerous cases addressing complex jurisdictional questions under taxation statutes and setting precedent favorable to clients regarding statutes of limitations. Laura is an editor of McDermott’s Tax Controversy 360 blog.
Laura L. Gavioli, PC, defends individuals and corporations in white-collar prosecutions, civil tax cases, US Internal Revenue Service (IRS) controversies …
Print and review course materials
Method of Presentation:
On-demand Webcast; Group-Internet Based
General knowledge of tax law
NASBA Field of Study:
Taxes - Technical
NY Category of CLE Credit:
Areas of Professional Practice
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