IRS Foreign Assets Tax Compliance & Audits – 2024 Updates

Spin to Win A Discount

This class will provide an overview of compliance obligations related to foreign assets; including but not limited to foreign bank accounts, foreign corporations, foreign gifts and estates, foreign partnerships, and more. This class will discuss when taxpayers have a duty to report these foreign assets, and the consequences for a taxpayer’s failure to timely report or disclose these foreign assets. Taxpayers may be selected for enforcement action by the IRS for their failure to report these foreign assets and we will discuss how to navigate those audits and enforcement actions.

Must Attend For

• When and how to file FinCEN Form 114

• Identify the appropriate penalty for willful failure to file an FBAR

• Choose which assets are reportable on Form 8938, 5471, 3520, and Form 3520-A.

• Identify the filing threshold for gifts from foreign corporations or partnerships

• Determine how to fix past non-compliance mistakes – intentional or inadvertent.

• Discuss eligibility requirements for the Streamlined Offshore Voluntary Disclosure Program

• This course will discuss the requirements for reporting worldwide income from all sources including foreign accounts, foreign corporations and partnerships, paying taxes on the income from those accounts and entities, and paying penalties for noncompliance. Topics addressed include: FBAR reporting and penalties, types of foreign assets, comparison of Form 8938 and FBAR, passive foreign investment companies, Form 5471, the Offshore Voluntary Disclosure Initiative, receiving foreign gifts and Form 3520, and much more.

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Presenter

Adam Fayne

Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money laundering and offshore tax compliance. Adam’s knowledge of tax law is informed by his former role as a Special Assistant U.S. Attorney with the Department of Treasury’s IRS.