The Internal Revenue Code and Title 31 (the Bank Secrecy Act) contain a litany of penalties designed to encourage taxpayers to timely and correctly file information returns associated with their foreign activities. In many cases, taxpayers forget to timely make these filings—and, in worse cases, the failure to report may be intentional. This course will provide tax professionals with an overview of the more commonly asserted international reporting penalties and review how to defend against the potential imposition of such penalties.
Learning Objectives:
Gray Reed & McGraw
Partner
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(469) 320-6030
Matt Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals, and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Matt brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships, and corporations.
Clients also rely on Matt to advise on best practices for preventing or minimizing the financial and criminal impact of government tax inquiries. He handles a variety of tax compliance and reporting matters, including preparing voluntary disclosures to remedy unfiled or incorrect tax returns, advising on international tax reporting and penalties, and preparing opinions on the tax consequences of major financial events such as lawsuit judgments and settlements and theft or other tax losses.
As a respected thought leader on complex tax matters, Matt is in high demand as a speaker and author on a wide range of topics. His articles have been published in national and regional publications such as the Journal of Practice and Procedure, Tax Notes, The Tax Adviser, and Today’s CPA.
Matt has also served as a tax law professor at the Southern Methodist University Dedman School of Law, where he taught law students Corporate Income Taxation.