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The New IRS Voluntary Disclosure Procedures (Domestic and Offshore)

THE NEW IRS VOLUNTARY DISCLOSURE PROCEDURES (DOMESTIC AND OFFSHORE)

Cost Free
Presentation Length 1.0 hour

Recorded DateMay 14, 2019
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The IRS officially ended the Offshore Voluntary Disclosure Program in September 2018, and has now revised the disclosure procedures for both domestic and offshore issues. Taxpayers with unfiled returns or unreported income who want to come into compliance and avoid certain penalties (including criminal exposure) need to understand the new procedures.

The presenter will discuss:


  • The history of the IRS’s voluntary disclosure programs

  • Penalties that taxpayers may face for significant unreported income or unfiled returns

  • What has changed with the new disclosure procedures

  • How to evaluate the various disclosure options for your clients (offshore and domestic)

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Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.
 
Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.
 
Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm. 

About Our Presenter

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Clark Hill is a multidisciplinary international law firm that draws on its attorneys’ comprehensive industry and policy knowledge, deeply held shared values, and a global network of premier firms and advisors to provide effective legal solutions and client-service excellence. One of the top 100 firms in the United States — with over 600 attorneys and professionals in 25 offices across the nation, as well as offices in Dublin and Mexico City, we are a committed partner to a diverse range of leading brands, forward-thinking businesses, public entities, nonprofit organizations and individuals. Our significant presence in Washington, DC, and our deep government relations and public affairs experience at every level help ensure that our clients’ voices are heard in the development of federal and state regulatory policy and legislation.