Transparency Tide or Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts

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    Get up to date on the new regimes governing the mandatory reporting of offshore financial assets.

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    Mandatory reporting of offshore financial assets by financial institutions has been expanding globally ever since the U.S., in the wake of the UBS scandal, passed the Foreign Account Tax Compliance Act (FATCA) as a complementary program to the Foreign Bank Account Report (FBAR). The Justice Department and IRS maintain that, despite these reporting regimes, a high percentage of U.S. taxpayers, including millions residing abroad, are still failing to comply. The IRS’ Criminal Investigation division recently unveiled two new investigative units: the International Tax Enforcement Group (ITEG) and the Nationally Coordinated Investigations Unit (NCIU)—both aimed at increasing taxpayer compliance using advanced data analytic techniques. Meanwhile, the Justice Department’s Swiss Bank Program – an amnesty program designed for Swiss financial institutions – is in its legacy phase and the IRS is closing (as of Sept. 28, 2018) its popular Offshore Voluntary Disclosure Program (OVDP) under which cooperating taxpayers could pay reduced penalties and avoid criminal sanctions. Both the Justice Department and IRS have broadened their efforts and are now investigating funds that flowed out of the scrutinized Swiss banks to banks in other countries. At the same time, an OECD transparency initiative, inspired by the FATCA and known as the Common Reporting Standard (CRS), is being adopted by an increasing number of jurisdictions on a bilateral and multilateral basis. Tax advisors with international components to their practices should be aware of the impacts and exigencies of both the FATCA and the CRS. The panel will discuss critical updates to the FATCA and FBAR reporting regimes, outline recent enforcement efforts by the Justice Dept. and IRS, and compare the OECD’s CRS to FATCA, including their respective impacts on funds. Tax planning strategies and policy implications will also be discussed, including how the automatic exchange-of-information programs are likely to affect taxpayer behaviors and compliance rates, professional tax advice, and the so-called tax gap in the U.S. and other jurisdictions.

    Featured Speakers

    Pamela A. Fuller, Royse Law Firm, New York, NY

    Nicole Cammarota, Senior Counsel, IRS Office of Chief Counsel (Large Business & International), New York, NY

    Matthew D. Lee, Fox Rothschild, Philadelphia, PA

    Gabriel Quihuis, Morgan Lewis, Boston, MA

    PLEASE NOTE: To receive CLE credit, each individual attendee must be logged into the webinar interface for the ENTIRE program (including the Q&A). Partial credit is not available for this program. Please see the CLE Informaton page for more details.

    Registration Fees
    $75 for Section of Taxation Members
    $150 ABA Member*
    $125 Young Lawyers
    $125 Government / Academic / Non-Profit
    $195 All other registrants
    Group Discounts Available: 5 or more: $60 per attendee; 10 or more: $50 per attendee. Please e-mail the tax section ( for group registration.
    FREE Full-time J.D., LL.M., or M.T. Candidates (Law student registrants will also receive membership in the Tax Section.)
    FREE Tax Section Members who are Law Professors
    FREE Press
    *ABA Member registrants will become Tax Section members for 2018-19.
    Fee includes an mp3 audio recording that is available within one week following the program date.
    Law Student registrants, who are current nonmembers, will also receive complimentary membership to the ABA and the Section of Taxation.

    Event Details




    Dec 12, 2018

    2018-12-12T13:00:00.000Z 2018-12-12T14:35:00.000Z Transparency Tide or Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts

    Get up to date on the new regimes governing the mandatory reporting of offshore financial assets.


    CLE Information

    The ABA will seek 1.50 CLE credit hours in 60-minute-hour states, and 1.80 credit hours of CLE credit for this program in 50-minute states. Credit hours are estimated and are subject to each state’s approval and credit rounding rules.

    Registration Information

    For more information on registering for the program, including a copy of the printable registration form, please visit the registration information page.

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    If you're unable to attend the live webinar, please consider ordering the on-demand version of this program.

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