If you are a US citizen or resident living abroad or thinking about moving abroad, or if you are a non US citizen/resident thinking about moving to the US or investing in the US then this episode is full of important things you need to be aware of.  Sebastien Chain joined Chamberlain Hrdlicka in 2011 and concentrates his practice on federal, state and local tax controversies, both civil and criminal, and he represents clients at the examination level, administrative appeals, and trial. He also advises clients on a variety of international and domestic transactions. Mr. Chain’s clients include domestic and foreign individuals, corporations, LLCs, partnerships, trusts and estates. Mr. Chain’s tax controversy practice has covered a wide range of issues, and he has successfully resolved cases that involved worker classification issues, deferred compensation, ordinary and necessary business expenses, accountable plans, aircraft, transfer pricing, hobby loss, domestic and international information return penalties, and IRS collection enforcement actions. Mr. Chain has also prepared and submitted several Private Letter Rulings requesting relief for late tax elections. Mr. Chain has extensive experience advising clients on the U.S. reporting requirements associated with owning foreign assets, and he represents clients with unreported foreign income and foreign assets become compliant with their U.S. obligations. He has represented over 100 clients in connection with the IRS’s various voluntary disclosure programs, including the 2009, 2011, 2012 and 2014 Offshore Voluntary Disclosure Programs, the Streamlined Domestic and Foreign Offshore Procedures, and the Delinquent Information Return and FBAR Submission Procedures.