Rectifying Non – Compliance with respect to the FBAR and/or Unreported Income from Non-U.S. (i.e., foreign) Bank and Financial Accounts
Since 2009, the IRS has had a strong focus on compliance with the Report of Foreign Bank and Financial Accounts (TD F 90-22.1), or “FBAR”, and unreported income from foreign (i.e., non-U.S.) bank and financial accounts. The IRS is now on its third iteration of the an offshore voluntary disclosure program and, in September of 2012, the IRS also opened a program for nonresident non-filers. In addition, the IRS has a procedure in place for those individuals who reported all of the income from their foreign accounts but simply failed to file the FBAR and other foreign-related information forms (i.e., Forms 3520 and 5471).
The IRS has rigidly applied the eligibility requirements for its OVDP and Streamlined Program. Many situations do not fit neatly within one program or the other so it can be difficult for attorneys/accountants to advise clients with respect to their options and the potential risks/benefits of each option. The webcast will provide more details on the various options available and insight from experience regarding the IRS’s processing of cases under the various options.
James M. Bandoblu Jr., Senior Attorney ,
Hodgson Russ LLP
- The FBAR and income from foreign accounts in general
- The IRS’s current and previous offshore voluntary disclosure programs
- The IRS’s procedure for filing late FBARs and other foreign-related information returns where there is no unreported income from the foreign accounts
- The IRS’s Streamlined Filing Compliance Procedure for Nonresident Non-Filers
- The Department of Treasury’s new mandate to e-file FBARs submitted after July 1, 2013
- The effect of FATCA on FBAR compliance
David Gannaway, MBA, CFE, CAMS, EA, Principal,
- Opting Out – Points to Consider
- Real Estate & Art Work – Double Counting
- FATCA notifications – Should clients enter into the OVDP
Who Should Attend:
- Tax Attorneys and Accountants
- Chief Financial Officers
- Corporate Tax Professionals and Financial Executives
- Financial Advisors and Money Managers
- Enrolled Agents
Hodgson Russ attorney James M. Bandoblu, Jr. concentrates his practice in federal and international tax law and business law. Mr. Bandoblu regularly counsels clients on tax and corporate issues related to business operations, acquisitions, and sales, as well as advantageous business structures for tax planning purposes. In addition, he advises international clients with respect to the tax implications of U.S. citizenship and lawful permanent resident status. Mr. Bandoblu regularly represents clients in tax controversies with the IRS and New York State Tax Department and in voluntary disclosure matters.
Hodgson Russ attorney James M. Bandoblu, Jr. concentrates his practice in federal and international tax law and business law. Mr. …
David Gannaway, MBA, CFE, EA is a principal in the firm’s Valuation & Forensic Services group. He is responsible for providing litigation consulting services in the areas of internal investigations, shareholder disputes, civil tax controversies and criminal defense. David joined Citrin Cooperman in March 2011 and is based in the firm’s New York City office.
A former Assistant Special Agent in Charge of the New York office of IRS Criminal Investigation, David is a financial fraud investigative specialist with experience in conducting and supervising white-collar crime investigations. He has extensive experience in representing clients before the IRS in the “Offshore Voluntary Compliance Program” involving international taxation and the disclosing of Foreign Bank Accounts under the Bank Secrecy Act. He also provided fraud and anti-money laundering training to corporations and government agencies.
David Gannaway, MBA, CFE, EA is a principal in the firm’s Valuation & Forensic Services group. He is responsible for …
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Method of Presentation:
On-demand Webcast (CLE)
NASBA Field of Study:
NY Category of CLE Credit:
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About Hodgson Russ LLP
Hodgson Russ attorneys facilitate the U.S. legal aspects of transactions around the world. The firm practices in every major area of law and generally uses multidisciplinary work teams to serve the specific, complex needs of its clients, which include public and privately held businesses, governmental entities, nonprofit institutions, and individuals. Hodgson Russ has offices in Buffalo, New York City, Albany, and Saratoga Springs, New York; Toronto, Ontario; and Palm Beach, Florida.
About Citrin Cooperman
Citrin Cooperman (www.citrincooperman.com) is a full-service accounting and consulting firm, providing a range of attest, assurance, tax, business advisory, valuation and forensic accounting services to clients across the globe. Citrin Cooperman has deep experience in a variety of industries, including entertainment, real estate, staffing and executive search, not for profit, architecture and engineering, auto dealerships, franchising and technology. Founded in 1979, Citrin Cooperman is an independent member firm of Moore Stephens.