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.
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.
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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