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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, July 11, 2024

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

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

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This webinar will update international tax advisers on the IRS' current campaign targeting foreign taxpayers and foreign income. Our astute panelist will discuss the IRS' current enforcement actions, outline managing an IRS examination, and highlight offshore voluntary compliance options.

Faculty

Mishkin Santa
Principal, Director of International Tax
The Wolf Group, PC

Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift & trust tax compliance, FBAR Assistance, foreign trust tax compliance, exit tax planning, EB-5 investor program, international assignment structuring and planning, offshore voluntary disclosure programs, foreign corporation (Subpart F, Transfer Pricing, E&P Studies), and asset protection planning. His client base includes U.S. citizens living overseas, U.S. nonresidents, EB-5 investors, U.S. domestic individuals and families, international businesses, international based families with investments in multiple jurisdictions and tax residency in multiple jurisdictions, U.S. citizens or residents who are beneficiaries of foreign trusts and who will receive gifts or inheritances from non-US persons,  and trustees of trusts with U.S. grantors or U.S. beneficiaries.


 

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Description

Danny Werfel and the IRS have promised to restore fairness to the tax system and recently reminded taxpayers "of their U.S. tax obligations … to incentivize taxpayer self-correction." Of particular concern is the IRS' focus on foreign taxpayers and U.S. taxpayers with foreign income. The IRS has included more scrutiny on FBAR violations as a Priority Area for Targeted Compliance Work in 2024.

In addition to hiring 3,700 employees to bolster its compliance initiative and the IRS' historical use of Discriminate Function (DIF) Scores, the Service now employs data analytics to hone in on tax evasion and reporting anomalies. Audits of nonresidents and taxpayers with foreign income are particularly risky. So-called eggshell audits can expose these taxpayers to higher risk, higher penalty violations, and criminal sanctions. International tax advisers and multinational taxpayers need to be aware of the current state of IRS examinations and prepare for these upcoming audits.

Listen as our international tax expert reveals how to assess audit exposure risks for U.S. residents and nonresidents with foreign ties.

Outline

  1. Update on IRS enforcement
  2. IRS examination approach
  3. Common examples of eggshell audits
  4. Assessing risk for income tax returns of residents
  5. Assessing risk for income tax returns of nonresidents
  6. IR 2023-166: high income, high net worth, non-filer initiatives
  7. Other examination areas
  8. Offshore voluntary disclosure
  9. What's next?

Benefits

The panelist will cover these and other critical issues:

  • The current state of IRS examinations of international taxpayers
  • Targeted examination areas for multinational taxpayers
  • Assessing audit risk for income tax returns for residents and nonresidents
  • Examples of common issues that generate eggshell audits
  • How the IRS uses the DIF score and data analytics in the audit selection process

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify specific areas the IRS is targeting for examinations of international taxpayers
  • Determine how data analytics is being used by the Service in the audit selection process
  • Decide how to assess audit risk for returns and holdings for multinational taxpayers
  • Ascertain how streamlined filing compliance procedures can be used to resolve reporting issues

  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).