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FBAR and FATCA Reporting Requirements


Understand the scope of U.

S. tax reporting obligations with respect to offshore assets and the potential penalties for non-compliance.Millions of U.S. taxpayers living both overseas and in the United States own assets that are kept offshore. The U.S. government believes that many of these taxpayers, with the assistance of foreign financial institutions and other individuals, have been holding their assets offshore to avoid U.S. income tax or hide criminal activity. IRS enforcement activity in this area has been heavy for the last 15 years and the IRS, through various information gathering techniques, has become quite adept at locating taxpayers who are non-compliant with their offshore asset reporting obligations. To avoid serious problems, U.S. taxpayers and their tax advisors need to be well versed in a complicated reporting scheme. This presentation will help attendees understand the scope of U.S. tax reporting obligations with respect to offshore assets, the potential penalties for non-compliance, and ways that taxpayers may remediate past non-compliance before the IRS commences a formal investigation. Attendees will also learn about the laws and processes that have been put into place to collect information on offshore assets and how technology is assisting with that effort. Finally, attendees will hear about recent FBAR litigation and how that is shaping IRS enforcements efforts. Offshore asset reporting can be a trap for the unwary, but it doesn't need to be.



Niles A. Elber

Niles A. Elber

Caplin & Drysdale

  • Member, Tax Controversy Practice, Caplin & Drysdale’s Washington, D.C. office
  • More than 20 years of experience representing clients in civil and criminal tax controversies; practice is broad, ranging on the civil side from IRS examinations, appeals matters, and proceedings in federal court while on the criminal side handling both administrative and grand jury tax investigations; has assisted hundreds of clients with their voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts.
  • Speaks regularly to accountants and tax lawyers on a variety of tax controversy topics
  • Co-authored BNA Tax Management Portfolio titled: Report of Foreign Bank and Financial Accounts (FBAR)
  • Fellow, American College of Tax Counsel; member, American Bar Association Section of Taxation – past chair, Civil and Criminal Tax Penalties Committee
  • J.D. degree, Tulane University; LL.M. degree in tax, New York University
  • Can be contacted at [email protected] or 202-862-7827
Benjamin Z. Eisenstat

Benjamin Z. Eisenstat

Caplin & Drysdale

  • Member, Caplin & Drysdale’s Washington, D.C. office
  • Specializing in assisting individuals and corporations in all manner of civil and criminal tax controversies
  • Regularly advises clients with offshore assets on coming back into tax compliance through the use of the IRS’s voluntary disclosure programs and streamlined filing compliance procedures
  • Represented clients as part of some of largest FBAR investigations in U.S. history
  • Co-author of the U.S. Offshore Account Enforcement Issues chapter of the LexisNexis Guide to FATCA and CRS Compliance and co-author of the BNA Portfolio on FBARS
  • Co-Chair of the Civil and Criminal Tax Penalties – Criminal Litigation Sub-Committee for the Tax Section of the ABA
  • Represented clients in criminal investigations connected to Mossack Fonseca as revealed in the Panama Papers

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