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Recent IRS OVDP Developments: How Will It Impact the 2018 Landscape

Recent IRS OVDP Developments: How Will It Impact the 2018 Landscape

Live Webcast Date: Thursday, August 23, 2018 at 12:00 pm - 1:00 pm (ET)
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Partner Firms

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Baker & McKenzie LLP
McDermott Will & Emery LLP

Baker & McKenzie LLP

Baker McKenzie has provided sophisticated legal advice and services to many of the world's most dynamic and global organizations since our founding in 1949. With a network of more than 4,200+ locally qualified, internationally experienced lawyers in 77 offices worldwide and 47 countries, Baker McKenzie has the knowledge and resources to deliver the broad scope of quality legal services required to respond effectively to international and local needs -- consistently, confidently, and with sensitivity for cultural, social, and legal practice differences.

Baker McKenzie’s 10,000+ lawyers, supporting professionals, and staff are citizens of more than 60 countries. Baker McKenzie’s professionals are admitted to practice in nearly 250 jurisdictions and have been educated at more than 1,200 institutions, including nearly all of the world's leading law schools.

Website: http://www.bakermckenzie.com/

McDermott Will & Emery LLP

McDermott Will & Emery is a premier international law firm with a diversified business practice. Numbering more than 1,000 lawyers, we have offices in Boston, Brussels, Chicago, Dallas, Düsseldorf, Frankfurt, Houston, London, Los Angeles, Miami, Milan, Munich, New York, Orange County, Paris, Seoul, Silicon Valley and Washington, DC. Further extending our reach into Asia, we have a strategic alliance with MWE China Law Offices in Shanghai.

Chambers USA has perennially ranked McDermott’s tax controversy practice in its highest tiers, with clients noting that our attorneys “provide a lot of good market knowledge.” The Legal 500 has also recognized McDermott as a leading firm in the tax controversy area, noting that we provide “excellent services for reasonable fees.” US News-Best Lawyers recently named McDermott “Tax Litigation Firm of the Year.”

Website: https://www.mwe.com/

Speakers
Kathleen Agbayani

Kathleen AgbayaniOf CounselBaker & McKenzie LLP

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...

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. 

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Laura L. Gavioli, P.C.

Laura L. Gavioli, P.C.PartnerMcDermott Will & Emery LLP

Laura L. Gavioli, PC, defends individuals and corporations in white-collar prosecutions, civil tax cases, US Internal Revenue Service (IRS) controversies and complex financial...

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.

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Kathleen Agbayani, Of Counsel
Baker & McKenzie LLP

Laura L. Gavioli, P.C., Partner
McDermott Will & Emery LLP
  1. History of OVDP (Kathleen)
  2. End of current OVDP (Laura)
    1. Where there be another program? (Kathleen/Laura)
    2. What do you do after the current OVDP ends? (Kathleen/Laura)
  3. Enforcement priorities (5471/3520) (Laura)
  4. Penalties (Kathleen/Laura)
  5. Statute of limitations (Kathleen/Laura)
  6. FBAR litigation (Laura)

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

This is a must attend event for anyone interested in understanding the impact of recent IRS OVDP developments to the tax compliance landscape in 2018 and beyond.

During this LIVE Webcast, you will hear:

  • Detailed guidance explained by the most qualified key leaders & practitioners.
  • Hear directly from key thought leaders
  • Interact directly with panel during Q&A

Be in the know! Click the “register” button as space is limited. Significant discounts apply to early birds.

 

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