Gain a greater knowledge of the duties of American taxpayers with offshore accounts, trusts companies and financial accounts.
Join this session, where taxation attorney Robert McKenzie will guide you on how you can competently advise your clients of the best methods to resolve filing omissions.
Learning Objectives:
- The multiple tax filing requirements for taxpayers with foreign income and assets
- The filing requirement of foreign trusts, corporations and partnerships, and their beneficiaries/partners/shareholders
- What to do when clients who should have filed didn't, and how to correct these failures
- The current disclosure options available to taxpayers including the current Offshore Voluntary Disclosure Program, streamlined disclosures, and quiet disclosures
- The ramifications for the non-compliant client should their failure be discovered by the IRS
- The facts to determine the best disclosure option for each client
- How to reduce penalties using the IRS's soon-to-expire voluntary compliance programs
Why Should You Attend:
The Internal Revenue Service (IRS) has been aggressively pursuing unreported foreign accounts since 2009. During that time, the IRS has offered various Offshore Voluntary Disclosure Programs (OVDP's).
On March 14, 2018, the IRS announced that the current OVDP would end soon. It is now imperative that you review the best way to help your clients to correct prior omissions for their undisclosed foreign financials.
Instructor
Robert E. McKenzie is a Partner of the law firm of Arnstein & Lehr LLP of Chicago, Illinois, concentrating his practice in representation before the Internal Revenue Service and state tax agencies. He has lectured extensively on the subject of tax representation. He has presented courses before thousands of CPA's, attorneys and Enrolled Agents nationwide.
He has made numerous media appearances including Dateline NBC and The ABC Nightly News. Prior to entering private practice, Mr. McKenzie was employed by the Internal Revenue Service, Collection Division, in Chicago, Illinois. Robert served as a member of the IRS Advisory Council (IRSAC) which is a group appointed by the IRS Commissioner to provide advice to him and his management team (2009 - 2011).
Mr. McKenzie was Vice Chair Professional Services of the ABA Tax Section (2003 - 2005). He is past Chairman of the Employment Tax Committee and past co-chair of the Task Force for Bankruptcy Legislation of the ABA Section on Taxation and past Chairman of the Chicago Bar Association Federal Tax Committee.
He was Dean of the National Tax Practice Institute (1998-2002). Mr. McKenzie is the author of REPRESENTATION BEFORE THE COLLECTION DIVISION OF THE IRS and coauthor of REPRESENTING THE AUDITED TAXPAYER BEFORE THE IRS and REPRESENTATION BEFORE THE UNITED STATES TAX COURT.
Mr. McKenzie has been selected for listing by Law and Leading Attorneys where he served on its Advisory Board. He has been elected to the American College of Tax Counsel and serves as Vice President of its Board of Regents.
Mr. McKenzie received his J.D. with High Honors from the Illinois Institute of Technology, Chicago Kent College of Law.