About the Course
Introduction
This CLE/CPE webinar will provide tax counsel and advisers guidance on recent developments in U.S. international taxation and related IRS guidance for foreign activities of individuals and companies. The panel will review complex international tax issues associated with cross-border activities and the implications of the One Big Beautiful Bill Act (OBBBA) and recent U.S. tax regulations and guidance, as well as discuss avoiding the assessment of penalties, additional tax liability, and potential audits.
Description
The IRS continues to aggressively assess penalties for failure to comply with reporting requirements of individuals and companies engaged in cross-border activities. Tax professionals must understand the U.S. international tax regime, key tax provisions impacting certain transactions, reporting requirements, and available tax planning mechanisms for U.S. individuals and companies.
Under current tax law, and in light of recent developments in the international tax landscape stemming from OBBBA, 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 serious civil and/or criminal penalties.
Listen as our panel provides guidance on the most complex aspects of international tax compliance, tax issues associated with cross-border activities, and the implications of recent U.S. tax regulations and developments, as well as discusses avoiding the assessment of penalties, additional tax liability, and potential audits.
Presented By
Mr. McCormick is an attorney with fifteen years of experience, focusing his practice on international taxation. He represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at large law firms, an accounting firm, and a boutique tax law firm, Mr. McCormick's client exposures have covered every conceivable area of American-side international tax matters. He has worked with clients located in over 130 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. Mr. McCormick's practice focus has facilitated an unparalleled expertise in the field; he is trusted by clients and advisors around the world to obtain optimal results on international tax matters. Mr. McCormick is licensed to practice in Pennsylvania and New Jersey. and regularly assists clients (particularly multinationals) with estate planning needs in these jurisdictions.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Thursday, July 16, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Overview of U.S. international tax compliance
II. Recent developments
A. OBBBA
B. Sourcing of income and expenses
C. U.S. foreign tax credit
D. Transfer pricing
E. FATCA and other withholding and reporting
F. Subpart F
III. Tax planning tips for individuals and companies
IV. Navigating IRS examinations and appealing penalty assessments
The panel will review these and other key concepts:
- An overview of U.S. taxation of cross-border activities
- Impact of OBBBA on tax planning
- Reporting requirements and methods for compliance
- Tax planning tools available to individuals and companies engaged in international transactions
- Appealing penalty assessments, handling audits, and litigation tactics
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