The Future of IRS Voluntary Disclosures in a Post-OVDP World (July 18, 2019)

Program Number: 2993

Program Date: 07/18/2019


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Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax noncompliance. These new procedures apply to both domestic and offshore voluntary disclosures, and in many ways, they replicate the procedures under the now-shuttered OVDP. In other ways, the new procedures are significantly different, particularly the new civil penalty framework, which calls for the imposition of a 50 percent penalty on undisclosed offshore financial assets, and a 75 percent civil fraud penalty on unpaid taxes. This program will trace the history of IRS voluntary disclosure programs, review key elements of the new regime announced in November 2018, and provide guidance to practitioners considering whether voluntary disclosures are warranted.

$95.00Audio CD Add to Cart

Available in states

California, Colorado Eligible, Florida, Georgia, New Jersey Eligible, New York, New York - BOTH New and Experienced Attorneys, Texas Self Study

Credit Information

50 minute credit hour - 1.0 General CLE Credit, based on a 50-minute credit hour
60 minute credit hour - 1.0 General CLE Credit, based on a 60-minute credit hour

State Program Numbers

Credit Eligible for BOTH Experienced and New Attorneys in NY


Matthew D. Lee, Esq.

Fox Rothschild LLP

Matt is a former U.S. Department of Justice trial attorney who focuses his practice in the areas of white-collar criminal defense and investigations, federal tax controversies, financial institution regulatory compliance and complex civil litigation.

Matt represents companies and individuals in federal grand jury investigations and criminal prosecutions in a wide variety of areas, including tax, money laundering, health care, securities, public corruption, antitrust, Foreign Corrupt Practices Act, False Claims Act and fraud offenses. He also frequently litigates federal and state civil asset forfeiture matters. In several instances, Matt has successfully persuaded law enforcement agencies to decline prosecution of his clients, including an individual who failed to file tax returns for several years, a small business owner suspected of underreporting cash sales, an individual who maintained undisclosed offshore bank accounts and a business owner suspected of structuring monetary transactions.

Matt also has significant experience conducting internal investigations and advising companies and boards as to whether to self-disclose suspected wrongdoing to law enforcement. Matt is also a member of the Criminal Justice Act panel for the Eastern District of Pennsylvania.

To read more of Matt’s Accomplishments – go to: