This session will analyze the various options that remain available to taxpayers for the disclosure of previously unreported foreign assets. We will compare the different legal standards applicable to each option and identify issues to be considered when correcting past non-compliance. Finally, we will also review current IRS international enforcement efforts.
Identify the factors to be considered when determining the proper course for disclosing past non-compliance.
Understand the current options available to the IRS for enforcement of foreign reporting requirements.