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FIGHTING FBAR AND OFFSHORE PENALTIES

Cost Free
Presentation Length 1.0 hour

Recorded DateOctober 19, 2017
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The IRS and DOJ continue to focus on international enforcement and are using data from offshore disclosure programs, FATCA, and the Swiss bank program to find U.S. citizens and residents with undisclosed offshore assets. Given the uptick in offshore and report of foreign bank account (FBAR) audits, tax professionals should understand the options available to challenge penalties for unreported offshore assets. This course will provide an overview of offshore enforcement, but will focus on challenging civil penalties in FBAR and offshore audits, administrative appeals, and litigation.

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.
 
Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.
 
Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm. 

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TSheets is a time tracking application designed and engineered for companies across multiple industries that need to track, manage and report time. Utilizing web-based, cloud computing technology that integrates with multiple platforms, smartphones and software programs, TSheets provides a customizable alternative to paper timesheets and punch cards to streamline HR and IT roles for businesses of all sizes—from freelance shops to corporations employing tens of thousands.