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Course Details

Time to Fess Up? The What, When, How, and Why of IRS Voluntary Disclosure Programs

Webinar: ID# 1020454
Recorded CD
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About This Course:
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, and the 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

History of IRS Voluntary Disclosure Programs
Current State of IRS Enforcement
Traditional Voluntary Disclosure Practice
  • Benefits
  • Requirements
  • Types of Taxpayers Who Would Benefit
Offshore Voluntary Disclosure Programs
  • OVDP
  • History
  • Requirements
  • Benefits
  • Streamlined Filing Compliance Procedures
  • History
  • Requirements
  • Benefits
  • Other Options
  • Delinquent Information Returns
  • Quiet Disclosures
Risks of Inaction
  • Civil
  • Criminal
About The Presenter

Matthew D. Lee
  • Partner in the Philadelphia office of Blank Rome 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
  • 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
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Time to Fess Up? The What, When, How, and Why of IRS Voluntary Disclosure Programs
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