American Bar Association American Bar Association


TX0113T1-description This panel will discuss matters relating to opting out of the IRS Offshore Voluntary Disclosure Initiative, including “opt-out” mechanics and procedures, and issues relating to examination, negotiation and settlement expectations arising in various “opt-out” scenarios. The panel will also emphasize procedural and substantive issues that are emerging in FBAR assessments and litigation.



Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY

David A. Breen, Senior Counsel, Office of Chief Counsel, SB/SE, IRS, Philadelphia, PA

Caroline D. Ciraolo, Rosenberg Martin Greenberg LLP, Baltimore, MD

David H. Dickieson, Schertler & Onorato LLP, Washington, DC

Mark E. Matthews, Caplin & Drysdale Chartered, Washington, DC

John C. McDougal, Special Trial Attorney, Small Business/Self-Employed Division, Office of Chief Counsel, IRS, Washington, DC

Richard J. Sapinski, Sills Cummis & Gross PC, Newark, NJ

Thomas J. Sawyer, Senior Litigation Counsel, Counsel for International Tax Matters, Tax Division, Department of Justice, Washington, DC

Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY

Earn CLE Credit


2.0 hours of General CLE credit in 60-minute states/2.4 hours of General CLE credit in 50-minute states have been requested in states accrediting ABA teleconferences and live audio webcasts.*

*Please visit CLE Information for more information about CLE credit.

Through the Looking Glass: Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties
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