Taxpayers who have failed to file FBARs and other international information returns can face serious criminal and civil penalties. Inevitably, legal issues will surface when a taxpayer attempts to become compliant. Professional advisors may ask, “Should we have a Kovel letter?” or “Did the taxpayer have reasonable cause?” If a reasonable cause statement is appropriate, who should write it?

There are several procedural options for delinquent taxpayers with foreign accounts to become compliant, including the Offshore Voluntary Disclosure Program, the Streamlined Filing Procedure, and more recently, the Delinquent International Information Return Submission Procedures and the Delinquent FBAR Submission Procedures. Each option has different requirements and penalties.

This course will review each procedure currently available to taxpayers, focusing on identifying which procedure is appropriate for a particular client, spotting legal questions and issues as they arise, and considering whether and when to involve an attorney.