Coming in From the Cold: The IRS Adopts A More Flexible Approach to Undisclosed Foreign Income and Assets
Date:
Oct. 20, 2020
Time:
A little over two years ago, the IRS closed the door on its long-running Offshore Voluntary Disclosure program. While the IRS still welcomes voluntary disclosures with the promise of no criminal prosecution, it has adopted a less regimented set of guidelines, giving Agents significantly more flexibility in determining the taxes and penalties that will be imposed on taxpayers who voluntarily come forward. The panel will discuss the new guidelines, as well as recent trends in how the IRS and DOJ are handling FBAR penalties and penalties imposed with respect to offshore reporting errors (Forms 3520, 5471, 8938, etc.). The panel will also touch on other options for resolving international tax and information return non-compliance where voluntary disclosure may not be appropriate.
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