The IRS’ Offshore Voluntary Disclosure Program (OVDP): Avoiding Significant Risks and Penalties
For the past years, offshore compliance has remained the top priority of the Internal Revenue Service (IRS) as shown by the numerous amnesty programs created to help taxpayers with their compliance, hence, avoiding unwanted legal and financial burdens arising from any potential violation. The Offshore Voluntary Disclosure Program (OVDP), one of the IRS' several amnesty programs, provides taxpayers with the option to resolve previous omissions, errors, and non-compliance issues.
Join a panel of key thought leaders, tax professionals and practitioners assembled by The Knowledge Group as they bring the audience to a road beyond the basics of the IRS’ Offshore Voluntary Disclosure Program and as they delve into the depth-analysis of the current trends and recent developments surrounding this significant topic. Speakers will also provide the audience with practical strategies to avoid significant risks and penalties arising from tax scams and schemes.
Key topics include:
- IRS OVDP – An Overview
- Offshore Tax Avoidance Penalties
- Compliance Challenges and Pitfalls
- Strategies and Best Practices
- Trends, Developments, and Recent Updates
Matthew D. Lee, Partner
Fox Rothschild LLP
Kathleen A. Agbayani, Of Counsel
Baker & McKenzie LLP
David Gannaway, Principal
PKF O’Connor Davies, LLP
- History of civil and criminal enforcement in offshore area (Matt)
- History of IRS voluntary disclosure programs and overview of current OVDP requirements and penalties (Kathleen)
- Other voluntary disclosure options – streamlined etc. (Kathleen)
- Whether to opt out (David)
- Evolution of willfulness concept and recent developments (Matt)
- Penalty considerations in offshore area (non-OVDP) (Kathleen)
- What’s next for offshore enforcement (what is IRS/DOJ going to do with all this data)? (David)
Who Should Attend:
- Tax Attorneys
- Foreign Investors
- Tax Preparers
- Tax Practitioners
- Tax Professionals
- In-house Counsel
- Private and Public Companies
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 …
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 …
David Gannaway is a Principal of PKF O’Connor Davies’ Litigation Support Group. With more than 25 years’ experience, he has served as both an IRS Special Agent, handling criminal investigations, and a private sector consultant, unraveling complex domestic and international white-collar financial fraud schemes across numerous business sectors, including healthcare, non-profit and financial services, among others. He is recognized for preparing meticulous damage calculations and successfully refuting the computations presented by opposing witnesses. With a widely-respected record of producing impressive and favorable results in criminal and civil trials at both the state and federal levels, Mr. Gannaway is an exceptional client advocate in tax controversies, white-collar criminal investigations, offshore IRS disclosure issues, shareholder disputes and settlement negotiations.
Mr. Gannaway is a frequent speaker at industry conferences and a thought leader in the areas of preventing and detecting fraud, money laundering, civil and criminal income taxes, regulatory compliance, the Foreign Corrupt Practices (FCPA) and Bank Secrecy Acts.
David Gannaway is a Principal of PKF O’Connor Davies’ Litigation Support Group. With more than 25 years’ experience, he has …
Print and review course materials
Method of Presentation:
On-demand Webcast; Group-Internet Based
Basic Knowledge in Taxation
NASBA Field of Study:
Taxes - Technical
NY Category of CLE Credit:
Areas of Professional Practice
Unlock All The Knowledge and Credit You Need
Leading Provider of Online Continuing Education
It's As Easy as 1, 2, 3
Get Your 1-Year All Access Pass For Only $199
About Fox Rothschild LLP
Fox Rothschild LLP is a national law firm known for excellent client service and agility in problem solving. With 800 attorneys in 22 offices nationwide, we provide a full range of legal services to public and private companies — from startups and family-run businesses to multinational corporations. The attorneys in Fox’s White Collar Compliance & Defense practice are seasoned trial lawyers. The team includes former federal and state prosecutors and a former SEC lawyer. We have extensive experience handling corporate compliance matters, internal investigations and criminal defense relating to health care fraud, securities and public corruption. Fox has the experience to guide and protect companies, businesses and individuals in today’s rapidly changing environment.
About 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.
About PKF O’Connor Davies, LLP
PKF O’Connor Davies, LLP is a full-service certified public accounting and advisory firm with a long history of serving clients both domestically and internationally. With roots tracing to 1891, nine offices in New York, New Jersey, Connecticut and Maryland, and more than 700 professionals, the Firm provides a complete range of accounting, auditing, tax and management advisory services. PKF O’Connor Davies is ranked 28th on Accounting Today’s 2017 “Top 100 Firms” list and is recognized as one of the “Top 10 Fastest-Growing Firms.” PKF O’Connor Davies is also recognized as a “Leader in Audit and Accounting” and is ranked among the “Top Firms in the Mid-Atlantic,” by Accounting Today. In 2017, PKF O'Connor Davies was named one of the 50 best accounting employers to work for in North America, by Vault.
PKF O’Connor Davies is the lead North American representative in PKF International, a global network of legally independent accounting and advisory firms located in 440 locations, in 150 countries around the world.