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Experience
Track record
IRS Voluntary Disclosure Program
Represented numerous individuals with undeclared bank accounts in offshore jurisdictions seeking amnesty under an IRS Voluntary Disclosure Program such as the Offshore Voluntary Disclosure Initiative (OVDI), Offshore Voluntary Disclosure Program (OVDP), Streamlined Domestic Filing Procedure, Streamlined Foreign Offshore Procedure, Delinquent FBAR Submission Procedure and Delinquent International Information Return Submission Procedure.
Offshore Voluntary Disclosure Program
Negotiated with IRS for a decrease in the civil miscellaneous penalty associated with the Offshore Voluntary Disclosure Program based on partial compliance, alternative statutory framework, etc.
TEFRA Partnership IRS examination
Represented TEFRA Partnership in IRS examination that was settled at the exam level obtaining seven figure penalty relief from the proposed adjustment.
Penalty advice on voluntary disclosure program
Successfully handled one of the first Taxpayer Advocate appeals out of the 2009 Voluntary Disclosure Program obtaining six figure penalty relief.
Offshore inheritance
Successfully represented an American citizen in an audit with a substantial unreported offshore inheritance, obtaining seven figure penalty relief.
Civil settlement with IRS
Negotiated the waiver of criminal penalties and a very favorable civil settlement with the IRS for a client who had previously completed a voluntary disclosure without completely disclosing foreign holdings as required under the terms of his closing agreement with the Internal Revenue Service.
FBAR and FATCA filings reporting
Advising a US green card holder with substantial holding abroad who had not properly reported his financial assets on an FBAR or on his FATCA filings through the US streamlined domestic offshore procedures, reducing otherwise applicable tax, interest and penalties significantly.
Talks
- 'Weekly Expert Hour: IRS Issues,' Surgent CPE Webinar - September 25, 2025, speaker
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'Weekly Expert Hour: Foreign Bank and Financial Accounts (FBARs),' Surgent CPE Webinar - August 7, 2025, speaker
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'How to Effectively Represent Clients Under Audit by the IRS,' Surgent CPE Webinar - July 30, 2025, speaker
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'Representing a Client in an IRS Audit,' Surgent CPE Webinar - July 22, 2025, speaker
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'Representing a Client in an IRS Audit,' Surgent CPE Webinar - May 13, 2025, speaker
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'IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process,' Strafford CPE Webinar - December 12, 2024, speaker
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'Navigating the U.S. and Abroad,' PKF O'Connor Davies | International Business Conference - December 10, 2024, panelist
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'2024 Tax Changes and Year-end Planning Opportunities (YT24),' Surgent CPE Webinar - November 14, 2024, speaker
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'Representing Clients Under Audit,' Knowfully Learning Group CLE webinar - October 23, 2024, speaker
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'Representing Clients Under Audit by the IRS,' All-Star Tax Webinar Series sponsored by Edward Jones - July 31, 2024, speaker
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'What’s Shaping Tax Controversy in the US: Leading Issues Examined,' The Knowledge Group CPE Webinar - October 11, 2023, speaker
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'What Tax Practitioners Should Know About the Current State of IRS Audits,' All-Star Tax Webinar Series sponsored by Edward Jones - July 12, 2023, speaker
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'Up-Close Look at the New IRS Voluntary Disclosure Program: Unraveling New Provisions and Hot Issues,' The Knowledge Group CPE Webinar - August 4, 2022, speaker
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'Weekly Expert Hour: Updated Voluntary Disclosure Program,' Surgent CPE Webinar - May 27, 2021, speaker
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'The Foreign Accounts Tax Compliance Act (FATCA): Regulatory Trends and Compliance Issues' The Knowledge Group CPE Webinar - February 27, 2020, speaker
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'Section 754 Step-Up in Basis: Understanding the Tax Issues for Partnerships and LLCs,' Surgent CPE Webinar - July 17, 2019, speaker
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'Foreign Bank and Financial Accounts,' Surgent CPE Webinar - June 11, 2019, speaker
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'Understanding the Foreign Account Tax Compliance Act,' Surgent CPE Webinar - June 8, 2019, speaker
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'Willfulness and the IRS Disclosure Programs: Are you compliant?,' The Knowledge Group CPE Webinar - October 11, 2017, speaker
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'Fully Using Tax Advantages of Limited Liability Companies,' National Business Institute (NBI) -August 4, 2017, speaker
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'Foreign Account Tax Compliance Act (FATCA),' All-Star Tax Webinar Series sponsored by Edward Jones - June 28, 2017, speaker
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'Foreign Account Tax Compliance Act (FATCA),' Surgent CPE webinar - June 9, 2017, speaker
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'Foreign Bank Account Reporting compliance and Voluntary Disclosure options,' Surgent CPE Webinar - March 6, 2017, speaker
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'Advanced FBAR and FATCA Reporting for Estate and Trust Administrators,' Surgent CPE Webinar - June 2016, speaker
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'Foreign Bank and Financial Accounts (FBAR),' Surgent CPE Webinar - June 9, 2016, speaker
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'FATCA Filings and FBAR Filings,' All-Star Tax Webinar Series sponsored by Edward Jones - October 2015, speaker
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'FBAR Issues for Beneficiaries, Trusts and Trustees, Estates and Executors,' Surgent CPE Webinar - June 2015, speaker
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'Weekly Expert Hour: Foreign Bank and Financial Accounts (FBAR),' Surgent CPE Webinar - June 9, 2015, speaker
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'Foreign Bank Account Reporting Compliance and Voluntary Disclosure Options,' Surgent CPE Webinar - June 5, 2015, speaker
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'US Offshore Voluntary Disclosure Program and Other Options to Address Unreported Income or Assets,' The 20th World Offshore Convention - November 2013, speaker
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'Tax Opportunities in Partnership and Disregarded Entity Formation,' Continuing Legal Education Seminar Tax Planning for Domestic Partnerships and Limited Liability Companies - March 2012, speaker
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'Tax Issues and Strategic Planning for Partnership and LLC Contributions,' Continuing Legal Education Seminar Tax Planning for Domestic Partnerships and Limited Liability Companies - March 2012, speaker
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'Partnership and LLC Equity for Service Providers and Other Tax Issues (and Opportunities) Arising from Management Structuring,' Continuing Legal Education Seminar Tax Planning for Domestic Partnerships and Limited Liability Companies - March 2012, speaker