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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, March 7, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

$347.00
CLE
CPE
ALL

This CLE/CPE webinar will provide tax counsel and advisers with a practical discussion of the tax implications, reporting requirements of cross-border activities, and issue-based examinations of foreign activities of individuals and companies. The panel will review complex international tax issues associated with cross-border transactions, discuss navigating the compliance and reporting obligations, and guide advisers on how to avoid the assessment of penalties, additional tax liability, and potential audits.

Faculty

Olga R. Beloded
Partner
Curtis, Mallet-Prevost, Colt & Mosle LLP

Ms. Beloded advises domestic and foreign corporations and high net worth individuals on tax aspects arising in connection with cross-border transactions, mergers and acquisitions and public and private securities offerings. She also regularly advises governments and state owned entities on international tax issues in investor-state arbitration proceedings and other international disputes, particularly in the area of oil and gas.

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Kristin E. Konschnik
Partner
McLemore Konschnik LLP

Ms. Konschnik has practised US tax law in London for most of her career (along with stints in New York and Connecticut). She enjoys learning about her clients’ circumstances and goals, and she works hard to make complex tax concepts more accessible so that clients are empowered to make informed decisions about what matters to them. Because Ms. Konschnik has practised in London for many years, she has significant experience helping clients navigate multiple tax systems. Her primary expertise is in working with owner-managed businesses in a cross-border context. Ms. Konschnik's clients include family-owned and closely-held businesses (and their owners), entrepreneurs, and private equity, real estate and venture capital fund principals. In addition to regular advisory work for her long-term clients, she frequently works with management teams in private equity buyout and roll-over transactions. 

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Description

The IRS continues to aggressively assess penalties for failure to comply with the reporting requirements of individuals and companies engaged in cross-border activities. The IRS continues LB&I-conducted compliance campaigns focused on international tax issues, resulting in increased scrutiny of taxpayer reporting of foreign assets.

In light of increased IRS focus, possessing an in-depth understanding of international tax rules and regulations will assist counsel and tax advisers in helping taxpayers maintain compliance and avoid IRS examination. A taxpayer's failure to properly adhere to reporting and filing requirements associated with cross-border activities and foreign assets can result in severe civil and criminal penalties.

Listen as our panel guides advisers on the most complex aspects of international tax compliance in connection with cross-border reorganizations (Form 5471), transactions with related parties for certain foreign-owned U.S. corporations (Form 5472), gifts from foreign persons (Form 3520), as well as FBAR and FATCA filing and reporting requirements, planning methods for cross-border activities, guidance on IRS issue-based examinations, and effectively handling audits.

Outline

  1. IRS protocol for issue-based examinations and guidelines for counsel
  2. Reporting standards and methods to avoid penalties and additional tax liability and ensure compliance
  3. Strategies for handling FBAR audits, opt-outs, appeals, and litigation

Benefits

The panel will review these and other key concepts:

  • Reporting requirements and methods for offshore compliance
  • Tactics in handling IRS issue-based examinations
  • Appealing penalty assessments, handling audits, and litigation tactics

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify tax implications of cross-border activities and foreign assets
  • Determine a taxpayer's risk of exposure to additional tax liability or penalties
  • Ascertain effective techniques in handling IRS issue-based examination

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure, international taxation, and acquisitions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.