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In the foreign information reporting context, arguably no form creates as much consternation in the context of penalty exposure as the Foreign Bank Account Report (better known as the FBAR). Statutorily, willful failures to file FBARs create massive penalty exposure: the greater of $100,000 or 50% of the balance of unreported accounts for the year in question (with a six-year civil statute of limitations). In the FBAR penalty context, the primary focus is typically given to the interpretation of the "willful" standard - and how it connects to maximum penalty exposure.
This webinar will delve into the critical topic of FBAR (Report of Foreign Bank and Financial Accounts) compliance, focusing on the implications of willful non-compliance. Participants will gain an understanding of the legal framework surrounding FBAR requirements, the concept of willfulness, and how intent impacts penalties and enforcement actions. Real-world examples and case studies will illustrate the consequences of willful violations and strategies to mitigate risk and defend against allegations.
· Summarize the FBAR reporting requirements - both direct and indirect
· Understand the purpose of FBAR requirements and the distinction between willful and non-willful violations.
· Evaluate applicable penalties (willful and non-willful) and detail case law interpretations of the willful standard to date
· Identify Internal Revenue Manual limitations to both willful and non-willful penalty assessment, as well as proactive disclosure options where prior reporting failures have occurred
· Learn about the penalties associated with willful non-compliance and their financial and legal implications.
· Gain insight into how courts determine willfulness and the evidentiary standards used.
· Explore practical strategies for maintaining compliance, rectifying past errors, and defending against enforcement actions.
If you or your clients have foreign financial accounts, staying compliant with FBAR regulations is crucial to avoid severe penalties. This webinar provides actionable knowledge to safeguard yourself or your clients against allegations of willful non-compliance. Tax professionals, CPAs, attorneys, and individuals with foreign accounts will benefit from expert guidance on navigating the complexities of FBAR. With increased IRS scrutiny on offshore assets, understanding the nuances of willfulness is more critical than ever for risk mitigation and legal defense.
· CPA - small firm
· CPA - medium firm
· CPA - large firm
· Enrolled Agent
· Tax professionals
· Attorneys
· Tax Attorneys
· Individuals with Foreign Accounts
Patrick McCormick is an attorney with over
a dozen years of experience, focusing his practice specifically on
international taxation. Mr. McCormick represents both business and individual
clients on all aspects of United States international tax rules, both from an
income tax and estate/gift tax perspective. He collaborates with Clatid
Compliance to help the tax practitioners and professionals stay current and
compliant.
Having previously served as a partner at a
large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s
client exposures have covered every conceivable area of American-side
international tax matters. Patrick has also represented every type of taxpayer
– from multibillion-dollar business enterprises and ultra-high net worth
individuals to startups and individuals with complex questions but limited
budgets. Mr. McCormick has worked with clients located in over 90 countries on
American tax considerations of multinational activities, cultivating
specialized knowledge in every area of United States international tax rules.
Patrick's explicit practice focus has
facilitated an unparalleled expertise in the field; he is trusted by clients
and advisors around the world to obtain optimal results on international tax
matters.
NASBA -
Clatid is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org.
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