On October 11, 2017 from noon to 2:00 pm pacific time, Jan Allen will speak on IRS FBAR and willfulness during a live webcast entitled:

“Willfulness and the IRS Disclosure Programs: Are You Compliant?”

The program will answer the questions of US taxpayers and foreign nationals who live and work in the United States who have bank and investment accounts outside of the US.  For many years, the US Congress and the IRS was convinced US taxpayers were shielding income and assets from the IRS using offshore accounts and multiple corporate shell strategies.  Congress worked with the US Department of the Treasury and the IRS to develop the Foreign Account Tax Compliance Act or FATCA.  FATCA forces sovereign nations and foreign banks and investment houses to comply with US demands or face exclusion from access to US Markets.

The Justice Department filed suit against major Swiss bank and financial institutions resulting in a huge financial settlement worth hundreds of millions of dollars.  FATCA requires foreign banks, investment houses and sovereign tax agencies to provide detailed account information directly to the IRS in electronic format disclosing the accounts, balances and transactions as well as taxpayer identification numbers and credentials.  The IRS wants to know clearly who has a “beneficial interest” in any foreign account.

These accounts have been required to be reported on the IRS Foreign Bank Account Report or FBAR for over 10 years.  The failure to list every account and accurate information regarding balances and related income exposes the US taxpayer to huge penalties and interest for each year in question.  IRS FBAR and willfulness penalties are based upon the highest accumulated balance at any point in a tax year, and have no relation to present balance or available funds. As a result, penalties often exceed the present value of the account.


The IRS created two Voluntary Disclosure Programs for US taxpayers to come into compliance with Foreign Bank Account Reporting or FBAR requirements: the Offshore Voluntary Disclosure Program or OVDP and the Streamlined Domestic (Foreign) Offshore Procedures.

In this LIVE IRS FBAR and willfulness webcast, a panel of thought leaders including Janathan Allen will discuss the significant and latest issues surrounding IRS FBAR Disclosure Programs. They will provide an in-depth discussion of Offshore Voluntary Disclosure Program (OVDP), Streamlined Disclosure Programs (SDP) and the role of willfulness in disclosing foreign accounts and assets. Speakers will also offer best practices in developing and implementing an effective guide to be compliant with the said programs.

Key issues that will be covered in this course are:

  • Foreign Account Tax Compliance Act (FATCA) – Overview
  • IRS Disclosure Programs
    • Offshore Voluntary Disclosure Program
    • Streamlined Disclosure Programs
  • What is Willfulness?
  • Recent Cases Involving Willfulness
  • Compliance Guides

Learn more about the program and request additional information by contacting us or calling 866-631-3470 for a free consultation.

Contact an Estate Planning, Business Law Or Tax Attorney Today

To set up a free, no-obligation consultation with one of our knowledgeable San Diego based estate planning, business and tax lawyers, or learn more about our tax preparation, accounting and business advisory services call us at 866-631-3470 or contact us.