Content Provider
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Middle parkway
Legalissues bovelanga


Cost Free
CPE Credits 1.0 hour
Subject Area Business Law
Course Level Basic
Instructional Method Group Internet Based
Prerequisites None
Advanced Preparation None
Course Description

Taxpayers who have failed to file FBARs and other international information returns can face serious criminal and civil penalties. Inevitably, legal issues will surface when a taxpayer attempts to become compliant. Professional advisors may ask, “Should we have a Kovel letter?” or “Did the taxpayer have reasonable cause?” If a reasonable cause statement is appropriate, who should write it?

There are several procedural options for delinquent taxpayers with foreign accounts to become compliant, including the Offshore Voluntary Disclosure Program, the Streamlined Filing Procedure, and more recently, the Delinquent International Information Return Submission Procedures and the Delinquent FBAR Submission Procedures. Each option has different requirements and penalties.

This course will review each procedure currently available to taxpayers, focusing on identifying which procedure is appropriate for a particular client, spotting legal questions and issues as they arise, and considering whether and when to involve an attorney.

Learning Objectives

  • Benefits and limitations of Kovel letters, and how to use them.

  • Learn the legal standards used in reporting procedures.

  • Identify legal issues and when to involve an attorney.

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Ruth helps clients implement comprehensive plans that meet their personal, family, and professional goals. As part of her estate planning practice, Ruth focuses on international planning, including planning for overseas assets, forming offshore asset protection trusts, planning for a spouse who is not a U.S. citizen, and helping U.S. beneficiaries plan to receive gifts and inheritances from abroad. For clients with unreported foreign assets, Ruth coordinates with accountants to help bring the clients into compliance with their FBAR and other reporting requirements. Additionally, Ruth advises trustees and Personal Representatives with the administration of trusts and estates, including local and multinational trusts and estates.

Handout Materials
Presentation Slides
Additional Materials
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NASBA Approved (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

About Our Presenter

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Vacovec, Mayotte & Singer, LLP is a law firm distinguished for its concentration in tax law. Located just outside of Boston, Massachusetts, we provide a full range of tax and related legal services to clients throughout the United States and around the world. Our attorneys are experienced in solving complex tax planning, structuring and compliance issues using creative strategies and determined advocacy on behalf of our clients. Please contact us for more information about our services and our firm.