This session will analyze the various options available to taxpayers for disclosures to the IRS of previously unreported foreign assets in light of the closure of the Offshore Voluntary Disclosure Program in August 2018. We will compare the different standards applicable to each option and identify the issues to be considered when correcting past non-compliance. Also current IRS international enforcement efforts will be analyzed.
Identify the factors to be considered when taxpayers disclose past non-compliance.
Recognize the current options available to the IRS for enforcement of foreign reporting requirements.