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THOUGHT LEADERSHIP/ALERTS

Webinar Recording: Voluntary Disclosure of Offshore Accounts—Chapter 2 (U.S./Canada/UK/France)

March 22, 2011
Author(s): David K. Cheng, Kenneth H. Silverberg

Originally recorded: Thursday, March 17, 2011
Click here to view an online recording of this webinar.

The IRS recently announced a new 2011 Offshore Voluntary Disclosure Initiative (OVDI) on February 8, 2011. Similar to the first voluntary disclosure program that ended in October 2009 with a total of 15,000 voluntary disclosures, it provides a limited window of opportunity for U.S. taxpayers to correct any previous omissions of offshore income from their U.S. tax returns without risk of criminal prosecution. Although the objective of the program is the same, the civil penalties are higher and the risk of getting caught has increased significantly.

For this new initiative, taxpayers have until August 31, 2011, to come forward and participate in the amnesty program. Taxpayers who do not submit a voluntary disclosure run the risk of detection by the IRS and the imposition of substantial penalties—including the fraud penalty, foreign information return penalties, and an increased risk of criminal prosecution.

To learn more about this important initiative, we invite you to join us while we discuss the following issues:

  • How did this all begin?
  • What has happened to those who participated in the 2009 program?
  • How is the new 2011 Voluntary Disclosure Initiative different from the 2009 program?
  • How does the new IRS initiative reduce the risk and cost of coming into full U.S. tax compliance?
  • Why should I make a voluntary disclosure? What are the benefits? What will it cost?
  • Is my name one of those that has already been disclosed to the IRS?
  • Can I safely evaluate how this would affect me before deciding to come forward?
  • How do I participate?
  • Practical dos and don’ts.

Panelists

  • Kenneth H. Silverberg, Partner, Nixon Peabody LLP
    ksilverberg@nixonpeabody.com
    Washington, DC: 202-585-8322
  • David K. Cheng, Partner, Nixon Peabody LLP
    dcheng@nixonpeabody.com
    San Francisco: 415-984-8342
    Shanghai: +86 21 6137 5568
    Hong Kong: +852 9307 3900

Recording

Click here to view an online recording of this webinar.


The foregoing has been prepared for the general information of clients and friends of the firm. It is not meant to provide legal advice with respect to any specific matter and should not be acted upon without professional counsel. If you have any questions or require any further information regarding these or other related matters, please contact your regular Nixon Peabody LLP representative. This material may be considered advertising under certain rules of professional conduct.