Keep you and your client safe by properly disclosing and correcting tax reporting problems.
In recent years, the Internal Revenue Service has strongly encouraged individuals and companies who are not fully compliant with their tax obligations to come forward and voluntarily disclose their noncompliance. Under certain circumstances, noncompliant taxpayers can obtain amnesty from criminal prosecution by coming clean. This topic will address the history of the various IRS voluntary disclosure programs, including its traditional voluntary disclosure practice for domestic issues, new procedures announced in November 2019, and the now-closed Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures for offshore issues. Review the parameters and requirements of each of these various disclosure programs, and outline how to choose which option is best. The topic will also address the various risks facing noncompliant taxpayers who fail to take appropriate action, including civil and criminal exposure. Gain unique insight into the current enforcement mindsight of the IRS, and learn the benefits of coming clean and the risks of inaction.
Agenda
Faculty
Matthew D. Lee
Fox Rothschild LLP
- Partner in the Philadelphia office of Fox Rothschild LLP
- Former U.S. Department of Justice trial attorney
- Practice emphasizes all aspects of white collar criminal defense and federal tax controversies
- Advises clients on FATCA and FBAR reporting requirements and IRS voluntary disclosure programs
- Counsels foreign banks on FATCA compliance issues
- Author of The Foreign Account Tax Compliance Act Answer Book 2017 (Practising Law Institute)
- Frequent speaker and writer on issues relating to the IRS voluntary disclosure programs, DOJ/IRS enforcement efforts regarding undeclared foreign bank accounts, and FBAR and FATCA rules and regulations
- Member of the Pennsylvania, New York, New Jersey and District of Columbia Bars
- J.D. degree, Emory University School of Law; B.A. degree, Furman University
- Can be contacted at 215-299-2765 or [email protected]
Jeffrey M. Rosenfeld
Blank Rome LLP
- Attorney in the Philadelphia office of Blank Rome LLP
- Concentrates his practice in the area of business tax law
- Counsels public and private corporations, partnerships, and individuals in a broad array of tax matters including domestic and international tax matters; state and local tax planning; tax-efficient structuring of domestic and international mergers, acquisitions, divestitures; reorganizations, spin-offs, redemptions and liquidations; formation, operation and acquisition of Subchapter S Corporations, partnerships and limited liability companies; federal, state, and local criminal and civil tax controversies, including audits, administrative appeals, and litigation; and issuances of equity-based compensation
- Counsels corporate clients and individuals regarding undeclared foreign bank accounts, including FBAR reporting obligations, and has represented numerous clients in the Internal Revenue Service’s Offshore Voluntary Disclosure Program
- Frequently writes on issues related to the FBAR and FATCA rules and regulations and international tax compliance issues
- J.D. degree, University of Pennsylvania Law School; L.L.M. degree, New York University School of Law; B.S. degree, Yeshiva University
- Can be contacted at 215-569-5752 or [email protected]
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