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The Future of IRS Voluntary Disclosures in a Post-OVDP World

THE FUTURE OF IRS VOLUNTARY DISCLOSURES IN A POST-OVDP WORLD

Cost Free
Presentation Length 1.5 hours

Recorded DateFebruary 11, 2019
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

On September 28, 2018, the Internal Revenue Service closed its long-running and hugely successful Offshore Voluntary Disclosure Program. Initially unveiled in March 2009, the OVDP proved to be the most successful tax amnesty program in IRS history, with over 55,000 taxpayers disclosing offshore assets and paying over $11 billion in back taxes, interest, and penalties.

Despite the closure of OVDP, the IRS and the Justice Department continue their unprecedented criminal and civil enforcement campaign against non-compliant taxpayers.

Voluntary disclosure options remain available to taxpayers, such as the Streamlined Filing Compliance Procedures and traditional voluntary disclosure practice, among others. This webinar will review all of the options available to non-compliant taxpayers and discuss the benefits and risks of various courses of action in the post-OVDP world.

PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Matt is a former U.S. Department of Justice trial attorney who focuses his practice in the areas of white-collar criminal defense and investigations, federal tax controversies, financial institution regulatory compliance and complex civil litigation. Matt maintains an extensive federal tax controversy practice in which he represents taxpayers in all stages of proceedings before the Internal Revenue Service, including examinations, appeals and collection proceedings. He regularly litigates cases in the United States Tax Court and other federal courts. He also represents clients in connection with highly sensitive so-called “eggshell” audits where indications of fraud may be present. In addition, Matt represents companies and corporate officers in connection with employment tax issues, including proceedings in which the IRS seeks to impose the Trust Fund Recovery Penalty on responsible corporate officers.

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Jeffrey M. Rosenfeld

Blank Rome LLP
Associate Tax Attorney
rosenfeld@blankrome.com
(215) 569-5752

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Jeffrey Rosenfeld concentrates his practice in the area of business tax law. He counsels public and private corporations, partnerships, and individuals in a broad array of tax matters including:

  • domestic and international tax matters
  • state and local tax planning
  • tax-efficient structuring of domestic and international mergers, acquisitions, divestitures, reorganizations, spin-offs, redemptions, and liquidations
  • formation, operation, and acquisition of Subchapter S Corporations, partnerships, and limited liability companies
  • federal, state, and local criminal and civil tax controversies, including audits, administrative appeals, and litigation
  • issuances of equity-based compensation
Jeffrey counsels corporate clients and individuals regarding undeclared foreign bank accounts, including “FBAR” reporting obligations, and has represented numerous clients in the Internal Revenue Service’s Offshore Voluntary Disclosure Program.
Jeffrey also has digital currencies industry experience, including:
  • Formation of entities to be engaged in the digital currencies space
  • Negotiation, drafting and documentation of governing documents (such as limited liability company agreement) for entities engaged in the digital currencies space
  • Compensation and other issues concerning the issuance of digital currencies or the grant of digital currencies to service providers
  • Federal income tax consequences associated with the purchase, sale or exchange of digital currencies

About Our Presenter

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Fox Rothschild LLP was founded in Philadelphia in 1907, and today the Philadelphia office continues as a cornerstone of the firm's strength. With more than 100 lawyers, the office has well-established practices in corporate law, financial services, labor and employment, litigation, real estate and taxation and wealth planning.

Fox Rothschild, which was named Pennsylvania's "Litigation Department of Year" for 2017 by The Legal Intelligencer, is one of the most well-respected firms in Philadelphia and serves business and civic leaders across the region.