Webinar: “New and Improved” June 2014 IRS Offshore Voluntary Disclosure Program – Version 3.0: Including “Streamlined” Rules that are a Game Changer Thursday, July 17, 2014, 12 noon – 1:30 p.m. (PST)

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The State Bar of California  – Taxation Section

Webinar: “New and Improved” June 2014 IRS Offshore Voluntary Disclosure Program – Version 3.0: Including “Streamlined” Rules that are a Game Changer

Thursday, July 17, 2014, 12 noon – 1:30 p.m. (PST)

Speakers:

•       Patrick W. Martin of (Procopio et al San Diego – ), who is the tax team leader of the firm’s tax practice and specializes in international tax matters, with a strong focus on international tax compliance

•       Mark E. Matthews of (Caplan & Drysdale in DC – ) focuses his practice on criminal tax enforcement, broad-based civil tax compliance and was Chief of the IRS Criminal Investigation Division, the agency’s investigative and law enforcement arm.

This program offers 1.5 hours participatory MCLE credit, 1.5 legal specialization credit in the area of Taxation Law and .5 hour credit in Legal Ethics. You must register in advance in order to participate.

Just days ago (June 2014), the IRS significantly revamped the “offshore voluntary disclosure program” (“OVDP”) that has existed since 2009. The new terms of the OVDP have now completely changed the “rules of the road” about how and when taxpayers can or should participate in such program. In addition, the so-called “streamlined” process has been changed in virtually all respects.

Learn – when should a taxpayer be considering the 2014 OVDP? When should a taxpayer not participate in the 2014 OVDP? When is an individual eligible? Learn important differences under the 2014 OVDP for those who reside in the U.S. versus U.S. citizens and lawful permanent residents who reside outside the U.S.

Understand the legal ramifications for those who sign certifications under penalties of perjury.

Understand the legal risks for financial, tax and legal advisers.

These changes create numerous legal risks for the unwary and for the financial, tax and legal advisers.

Find out how you can best assist your clients and minimize their legal risks, while simultaneously complying with the labyrinth of rules imposed by the Internal Revenue Service, including modifications to their own terms. This Webinar is appropriate for tax lawyers, non-tax lawyers (such as trusts and estate lawyers and business lawyers), certified public accountants, bankers, trust officers, trustees, enrolled agents and others who have clients who have assets located outside the U.S.

A detailed highlight of the new rules of circular 230 and their application in light of these changes to the OVDP will be discussed, along with other important ethical considerations and practice pointers.

Understand the legal ramifications of U.S. taxpayers who sign certifications under penalties of perjury, specifically including those required by the OVDP. How will United States citizens and lawful permanent residents (“LPR”) who are residing outside the United States view these rules? What are the pitfalls of the revisions in this program? How does the recent jury verdict in the willfulness FBAR 50% penalty case (with 150% penalty found by the jury) in Zwerner affect decisions of taxpayers and their advisers?

This webinar is taught by experienced tax lawyers, all former employees of the IRS, including a former Chief of the IRS Criminal Investigation Division, including experts who specialize in international tax related matters and advising those with worldwide assets; multi-national families and U.S. citizens and LPRs residing outside the U.S.

Extensive written materials will be provided that analyze the law, consider various legal implications of the 2014 OVDP. The course will specifically focus on current trends and developments of the IRS and Tax Division/Justice Department and current civil and criminal cases moving forward.

Plus, understand the basics of FATCA (the Foreign Account Tax Compliance Act) now in effect for 2014 and how this affects this arena of practice and international tax compliance. Specifically understand the role of FATCA under the new IRS modifications to the OVDP and why it is more important than ever.

Finally, some key income tax concepts of residency and international information reporting requirements under Title 26 and Title 31 will be briefly analyzed in the context of the 2014 OVDP.

Moderator: Eric D. Swenson of (Procopio et al San Diego – http://www.procopio.com/attorneys/eric-d-swenson) is a tax attorney with multiple years at Chief Counsel in the IRS and handles complex tax controversy and defense cases against the IRS and State taxing authorities.

Speakers:

•       Patrick W. Martin of (Procopio et al San Diego – http://www.procopio.com/attorneys/patrick-w–martin), who is the tax team leader of the firm’s tax practice and specializes in international tax matters, with a strong focus on international tax compliance

•       Mark E. Matthews of (Caplan & Drysdale in DC – http://www.capdale.com/mmatthews) focuses his practice on criminal tax enforcement, broad-based civil tax compliance and was Chief of the IRS Criminal Investigation Division, the agency’s investigative and law enforcement arm.

To register, see Webinar: “New and Improved” June 2014 IRS Offshore Voluntary Disclosure Program – Version 3.0 or go to http://www.calbar.org/online-cle and select Taxation or Webinars.

 

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