International Tax Issues Facing U.S. Taxpayers With Foreign Accounts and Their Financial Institutions

Date: March 18, 2010

Time: 9:30 AM - 12 PM

Program Description: The seminar will provide an update on the developments in Singapore to incorporate the standard OECD Exchange of Tax Information.

This will be followed by a discussion on tax, reporting requirements and voluntary disclosures relating to foreign accounts maintained by American taxpayers, and how those issues may affect both account holders and financial institutions. The roles of foreign corporations, trusts and the involvement of professional intermediaries will be addressed, as will estate and gift tax matters, the QI program, and institutional and corporate civil examinations, criminal investigations and voluntary disclosures.

The speakers will elaborate on the processes available to the United States to obtain offshore information through treaties and other means including potential Congressional action under the Obama Administration's proposed compliance measures as well as the proposed Foreign Account Tax Compliance Act currently put before the Congress.

Potential civil and criminal sanctions for compliance violations will also be highlighted. The enforcement aspects will focus on the respective roles of the IRS and the Department of Justice including their increased presence abroad.

Speakers:
Scott D. Michel
Member and Managing Partner, Caplin & Drysdale

H. David Rosenbloom
Member, Caplin & Drysdale

Stephen Phua
Associate Professor, National University of Singapore