IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process
Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Thursday, November 20, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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This CLE/CPE webinar will provide tax professionals and advisers with an in-depth discussion of the IRS examination of taxpayers living abroad. The panel will focus on Section 965 transition tax, exit tax, and critical issues for non-filers; guide tax practitioners through the examination process; and explain best practices to withstand the ongoing scrutiny of these taxpayers' returns.
Mr. Giordano-Lascari is a Partner in the Private Client Services Group with nearly two decades of experience in advising high-net-worth individuals and closely-held businesses with international income tax and estate planning issues.
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
The IRS has and continues to audit a higher proportion of ex-pat tax returns. The rules for these nonresidents are often the reverse of those for residents. The filing status Married Filing Jointly can require a special election. Self-employed taxpayers usually are not entitled to deduct expenses. A simple presence in the U.S. for 183 days can trigger capital gains. Remarkably, two-thirds of expats file these complicated returns on paper.
The IRS continues its compliance campaign focusing on Section 965 transition tax payments. The Service required these payments by U.S. shareholders of certain foreign corporations on unrepatriated (untaxed) earnings as part of the 2017 Tax Act.
Tax professionals and advisers working with individuals who have relocated abroad must understand the issues triggering these IRS audits, prepare clients for these audits, and know how to handle these demanding examinations.
Listen as our panel of foreign tax experts discusses reporting requirements of expatriates, outlines issues for non-filers, guides tax practitioners through the examination process, and explains best practices to withstand the ongoing scrutiny of these taxpayers' returns.
I. Reporting requirements for expatriates
II. Common expat audit issues
A. Non-filers
B. Filing status
C. Unreported capital gains
D. Information reporting returns
E. Unallowed business deductions
F. Other areas
III. Latest IRS expat compliance campaigns
A. Section 965 transition payments
B. Exit taxes and unsubmitted Forms 8854
IV. Examination process
V. Best practices
The panel will cover these and other critical issues:
- Which expatriate returns are being targeted by the IRS?
- How to best handle unfiled returns, including FBAR filings
- When should a taxpayer consider an appeal?
- What additional issues are being reviewed during Section 965 examinations?
- How can expats and tax advisers best prepare for IRS examinations?
Learning Objectives
After completing this course, you will be able to:
- Determine which taxpayers may be at greater risk for an IRS expat examination
- Decide when and how going to appeals could benefit the taxpayer
- Identify specific steps expatriates can take to prepare for an IRS examination
- Ascertain when the filing status Married Filing Jointly may require an election
- 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.
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
