IRS Foreign Compliance and Audits

This session, led by tax attorney Adam S. Fayne, will provide a comprehensive overview of compliance obligations related to foreign assets—including, but not limited to, foreign bank accounts, foreign corporations, foreign gifts and estates, and foreign partnerships. The session will address when taxpayers are required to report these foreign assets and the potential consequences of failing to do so in a timely manner. Taxpayers who do not meet their reporting obligations may face IRS enforcement actions. This session will also guide attendees on how to navigate related audits and enforcement proceedings.

Webinar Objectives

Participants will gain a thorough understanding of:

The duty to report worldwide income and foreign financial assets
Applicable forms including FBAR (FinCEN Form 114), Forms 8938, 5471, 3520, and 3520-A
How and when to file required disclosures to stay in compliance
Penalties for non-compliance, including those for willful FBAR violations
Resolving past reporting failures—whether intentional or unintentional
The Streamlined Offshore Voluntary Disclosure Program and other remediation options

Webinar Highlights

When and how to file FinCEN Form 114
Penalties for willful failure to file an FBAR
What qualifies as a foreign asset and where it must be reported
Gift and inheritance thresholds triggering Form 3520 filing
Comparing Form 8938 and FBAR reporting requirements
Understanding and reporting interests in passive foreign investment companies (PFICs)
Filing obligations for owners of foreign corporations and partnerships (Form 5471)
How to qualify for offshore voluntary disclosure programs