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.
Identify tax rules and disclosure options that apply to taxpayers who are not compliant with their tax reporting obligations, including those with undisclosed offshore financial assets.
Matthew D. Lee is a partner at the law firm of Fox Rothschild LLP in Philadelphia. He is co-chair of the firm's White-Collar Criminal Defense & Regulatory Compliance practice group, and maintains an extensive tax controversy practice. Mr. Lee regularly represents individuals and businesses in criminal and civil tax matters, including criminal tax investigations and prosecutions as well as proceedings before the Internal Revenue Service such as audits, Appeals, and collection matters.
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:
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