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The IRS and DOJ continue to focus on international enforcement and are using data from offshore disclosure programs, FATCA, and the Swiss bank program to find U.S. citizens and residents with undisclosed offshore assets. Given the uptick in offshore and report of foreign bank account (FBAR) audits, tax professionals should understand the options available to challenge penalties for unreported offshore assets. This course will provide an overview of offshore enforcement, but will focus on challenging civil penalties in FBAR and offshore audits, administrative appeals, and litigation.
James, PA
"Attorney Wu is a good speaker, and has vast subject knowledge. I have not had an FBAR case that is being litigated. I have had to research this area on my own for a taxpayer that used a broker that bought securities all over the world. It is indeed complicated, and fraught with pitfalls."
Robin, AK
"Great session. Tricky subject but the instructor cut through to what is being done and what you as a practitioner should do. Joshua Wu does a very good job of explaining difficult areas of practice."
RENE, PA
"The webinar provided great information on a topic that is being seen more and more frequently. The instructor was very knowledgeable and presented the material very well."
Cheryl, KY
"Excellent presenter. Love background info (meaning history of legislation etc) and insight info and this presenter provided both."
Paul, CA
"If Joshua is presenting, the information is valuable, your time is well spent, and the presentation is smooth and easy."
Rosemarie, FL
"Very effective presentation. Well crafted and focused on topic. Look forward to all presentations by this speaker."
Kim, MO
"I always learn something new from webinars done by Joshua Wu. He's extremely knowledgeable and comprehensive."
Kay, IA
"The instructor was outstanding. Obviously knowledgeable and very articulate presentation. Thank you so much!"
Joshua Wu
Latham & Watkins LLP
Counsel
joshua.wu@lw.com
(202) 637-3376
Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.
Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.
Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm.
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