Are You Aware of the
Recent Reporting Requirements for
Offshore Assets and Accounts?

(and What You Can Do If These Have Gone Unreported?)

Recently, the IRS has made significant changes to programs that allow taxpayers to come into compliance with their unreported and undisclosed offshore assets and accounts.  It’s important as estate and tax planners that you are on top of the reporting requirements and these new delinquent submission options, to provide the best possible planning and recommendations for your clients.

Please join us and nationally renowned estate and tax planning attorneys, Neda Barkhordar and Bruce Givner, for a special 2-part program entitled, “Reporting Requirements for Foreign Assets & Transactions.”

On Part 1, entitled, “Everything You Should Know Regarding the FBAR and Offshore Asset Voluntary Disclosure Alternatives”, Neda will cover in 90-minutes:

  • When a taxpayer must file a Foreign Bank Account Report (“FBAR”), what requirements are needed to meet eligibility, penalties for failure to disclose and what documents need to be submitted.
  • The different reporting alternatives available and requirements for each program.
  • How to decide which alternative is best for your clients with the use of examples, including how to best determine if your client meets the “non-willful” standard to be eligible for the Streamlined Compliance Submission.
  • Procedures for filing delinquent FBAR and International Information Returns.
  • Who and where to contact within the IRS for your clients pertaining to FBAR and Offshore Voluntary Disclosures.
  • And much more!

On Part 2, entitled, “Read Them and Weep!!! The Top IRS Foreign Information Returns (Other Than FBARs and FATCA)”, Bruce will cover in 90-minutes:

  • Form 3520 – Needed, for example, when a client receives a gift of more than $100,000 from an NRS
  • Form 3520A – Foreign trust with a U.S. owner – failure to file is the greater of $10,000 or 5% of the gross value of the trust assets
  • Form 5471 – U.S. shareholders of what might be a controlled foreign corporation
  • Form 5472 – 25% foreign-owned U.S. corporation or a foreign corporation engaged in a U.S. trade or business
  • Form 926 – U.S. transferor of property to a foreign corporation
  • Form 8865 – U.S. persons with interests in foreign partnerships
  • Form 8858 – U.S. persons with interests in foreign disregarded entities
  • Form 8621 – Shareholder of a PFIC
  • And more!

You have the option to register for each program individually, or save almost 20% when you register for both programs in this series!

  • Program Title: Reporting Requirements for Foreign Assets & Transactions – 2-PART SERIES
  • Speaker: ,
  • Duration: 90 minutes each

Bruce Givner

Esq.
Bruce Givner

Bruce Givner, Esq. is an estate and tax planning attorney of the Law Firm of Givner and Kaye, located in Los Angeles, California. Mr. Givner graduated from U.C.L.A., Columbia University Law School, and N.Y.U.’s Graduate Tax Law Program and specializes in the area of asset protection and advanced estate planning. He has personally worked with Mr. Philip Kavesh for over 30 years and continues to serve “of counsel” to Mr. Kavesh’s law firm, Kavesh, Minor and Otis, Inc.

Mr. Givner has been cited as a “tax expert” by the U.S. Tax Court, the California Court of Appeals, and the Wall Street Journal. He’s also written books on estate tax planning for the California CPA Society and the AICPA, and has co-authored three for the California Bar Association. He represented the winning taxpayers in the 1994 Tax Court case L&B Pipe and Supply, in which the IRS sought almost $2,000,000 in back taxes and interest due to alleged unreasonable compensation. The U.S. Tax Court awarded the IRS nothing.

His most recent Tax Court case, involving an FLP established on August 3, 2002, where the parent died on August 8, 2002, settled one month before trial when the IRS conceded that IRC §2036 did not apply.

Neda Barkhordar

Esq.
Neda Barkhordar

Neda Barkhordar is an associate at the Law Offices of Givner & Kaye, APC, out of Los Angeles, California.  Neda joined the firm in the Fall 2012.

She is a graduate of UCLA, where she completed her degree in 3 years summa cum laude; she received her law degree from UCLA where she completed the Business Law and Policy Specialization in Taxation and received A’s in all of the major tax classes; and she earned her LL.M. in tax from New York University.

Neda has advised clients on both regular estate planning, such as pourover Wills and family trusts, and complex estate tax planning involving private annuities, QPRTs, SCINs and GRATs. She has been the primary advisor to clients and their other advisors about the Offshore Voluntary Disclosure Program (taxpayers with delinquent Foreign Bank Account Reports). Neda is constantly working on inbound planning (non-U.S. people who wish to invest in the U.S. or give assets to their U.S. family members), multi-national planning (clients with assets in the U.S. and other countries, e.g., Germany, Russia and France) and other problems, including innocent spouse, offer-in-compromise and installment agreements. Neda has filed Tax Court petitions and is actively engaged in negotiations with the Internal Revenue Service and the California Franchise Tax Board on behalf of taxpayers with collection and other problems. She is also currently at work on two large tax-free spin-offs under Internal Revenue Code Section 355. And those are just a few of her past and current projects.

IMPORTANT NOTICE REGARDING CE CREDIT

The Ultimate Estate Planner, Inc. and the presenter are not registered Continuing Education Sponsors and this program is not pre-approved for continuing education credit for any state or regulatory agency.

However, please note that each program includes a Certificate of Completion and, depending on the license and the regulatory agency for which governs a participant’s CE credit, some professionals may be able to self-report his or her participation and receive credit. It is the responsibility of the participant to complete any process necessary to seek self-reported CE credit for his or her participation. By registering for a teleconference (or purchasing on On-Demand program), you understand that CE credit is not guaranteed or warranted by the presenter or The Ultimate Estate Planner, Inc.

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