Through the Looking Glass (Parts I and II): Opting Out…
Through the Looking Glass (Parts I and II): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties
Date:
January 16, 2013
Location:
Webinar
Speaker(s):
Richard J. Sapinski
Sponsor:
American Bar Association Section of Taxation
This panel will discuss matters relating to opting out of the IRS Offshore Voluntary Disclosure Initiative, including “opt-out” mechanics and procedures, and issues relating to examination, negotiation and settlement expectations arising in various “opt-out” scenarios. The panel will also emphasize procedural and substantive issues that are emerging in FBAR assessments and litigation.
