Offshore Voluntary Disclosures of Previously Unreported Foreign Financial Accounts and Income

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Offshore disclosures.jpg

Offshore Voluntary Disclosures of Previously Unreported Foreign Financial Accounts and Income

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This webinar is designed for the tax professional seeking a practical understanding of available programs for the voluntary disclosure of unreported foreign accounts and income.  This webinar will discuss:

  • Outline the ten alternative disclosure programs and procedures and how to determine the best one for your client
  • Explain qualification for the Streamlined Filing Procedures with its no or low penalty regime
  • Review drafting of the non-willful statement required under Streamlined Filing Procedures
  • Explain the risks of the Streamlined Filing Procedures
  • Compare Streamlined Filing Procedures to the 27 ½% to 50% penalty structure and closing agreement under the Overseas Voluntary Disclosure Program (OVDP)
  • Review processing of applications under Streamlined Filing Procedures and OVDP
  • Review delinquent filing procedures for FBARs and other international reporting forms
  • Explain the preparation of a reasonable cause statement for attachment to a delinquent filing of international reporting forms
  • Outline the evaluation of criminal risk for the non-compliant client

About Your Instructor: William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments.  He is also a member of the firm’s Tax Litigation and Controversy Group.  He is a Certified Specialist in Taxation Law.  In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriations of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court.  Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law.  He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch.  He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute.  In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation.