Niles Elber to Moderate Panel on the Latest Developments in Offshore Opt Outs and Examinations at ABA 2014 Midyear Meeting
Nearly five years after the first OVDP, there appears to be no end in sight to the IRS's efforts to combat offshore tax evasion, and the playing field is only becoming more complex. How can the tax practitioner keep track of it all? This panel, largely focusing on civil matters, will provide an update on current IRS priorities and discuss some of the more challenging aspects of representing taxpayers with offshore compliance issues. Among the topics that will be covered are opt‐outs, audits of taxpayers that made "quiet" disclosures, streamlined submissions, and what's happening with offshore cases that reach IRS Appeals.