A big thank you to Adam Karp, Chairman of the Tax Section International Committee for inviting Krista Hartwell, Kurt Kawafuchi and me to participate as the featured speakers for their web meeting.  We had a lively discussion on a variety of topics such as:

  • Ending of the OVDP program by the IRS in September
  • International Tax Enforcement by the IRS
  • Section 965 Repatriation
  • The Colliott case regarding the decision to cap the FBAR willfulness civil penalty at $100,000