The objective of this course is to advise practitioners and taxpayers of new IRS' rules and regulations governing the report and the taxation of income from foreign bank accounts
and foreign assets; and the penalties and relief provisions resulting from the holding of
unreported foreign assets and foreign bank accounts by United States taxpayers.
Topics to be covered in this course will be:
- The Offshore Voluntary Disclosure Program providing Amnesty and tax relief for
taxpayers who have not filed U.S. information or tax returns reporting foreign holdings or income;
- The Streamlined Disclosure Procedure applicable to individuals who have not been
willful in their failure to file United States tax and information returns on foreign
assets;
- Forms required to report foreign bank accounts of U.S. taxpayers;
- Forms required to report foreign assets of U.S. Taxpayers;
- Penalties that apply to unreported foreign assets and foreign bank accounts;
- The United States is putting tremendous pressure on foreign banks to reveal their U.S. bank deposits. At the same time, it has provided several programs for U.S. persons that hold foreign accounts. There are several options to comply with U.S. laws. Each compliance option leads to significant accounting work. This includes clients that must prepare eight years of amended returns to insure they will avoid criminal penalties and other expensive penalties related to the failure to file information on foreign assets and accounts.
- Understanding of the term "willfulness" as applied to the United States tax laws;
A review of all forms and certifications that must be filed to comply with United
States "FACTA" laws;
- Advice for United States residents who have failed to file tax returns on foreign
holding;
- Advise for United States taxpayers not living in the United States on forms to file for
compliance with all Untied States tax laws
Lehman Tax Law
Tax Attorney
rlehman@lehmantaxlaw.com
(561) 368-1113
Over the past 38 years, Richard S. Lehman has established a sophisticated private practice focusing on tax law. His background, education, and experience has distinguished him in this complex field. A published author and noted speaker, Mr. Lehman has carved a reputation as a powerful client advocate. He is a graduate of Georgetown Law School with a Master’s of tax law from New York University Law School and four years of government service as a senior attorney with the Chief Counsel’s Office of the Internal Revenue Service and as a law clerk on the U.S. Tax Court. Unique to his practice is his position as a sole practitioner. A one-time partner in one of the nation’s largest law firms, Mr. Lehman has found that practicing on his own matches his client’s entrepreneurial spirit. Central to Mr. Lehman’s practice is recognizing that legal needs do not exist in a vacuum.
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