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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, July 16, 2020

  • 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.

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

$347.00

This course is $0 with these passes:

CLE
CPE
ALL

This CLE/CPE course will guide tax professionals and advisers on critical tax presence and residency issues for individuals and businesses stemming from COVID-19.

Faculty

Beth D. Tractenberg
Partner
Steptoe & Johnson PLLC

Ms. Tractenberg guides high-net-worth individuals, families, and fiduciaries in international and domestic estate planning, contested matters, estate administration, the creation and advising of exempt organizations, and drafting and negotiating prenuptial agreements. Ms. Tractenberg, who heads Steptoe’s Private Clients practice, provides comprehensive tax, personal, and business advice to families, working closely with their family offices and other advisers. Drawing on her tax and trusts and estates experience, she serves clients as a personal and family adviser on numerous business, management, and related personal issues, including issues involving real estate and business holdings in the United States and abroad. Ms. Tractenberg has extensive experience advising international clients on cross-border and pre-immigration planning, gifting, estate planning, and other tax issues. She frequently assists in resolving business disputes and sensitively guides succession planning across generations of family members.

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Amanda P. Varma
Partner
Steptoe & Johnson PLLC

Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax matters, with particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses across a variety of industries, regularly advising on the US tax consequences of cross-border investments, reorganizations, business restructurings, acquisitions, and financings.

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Lauren Azebu
Attorney
Steptoe & Johnson PLLC

Ms. Azebu focuses on taxation issues for both domestic and foreign clients. Her experience includes planning and structuring corporate transactions, FATCA compliance, and the Swiss-US Non-Prosecution Agreement program. Ms. Azebu also is actively involved in Steptoe's pro bono program, and has assisted several clients in settling tax issues with the IRS and state tax agencies.

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Description

The health risks of COVID-19 and federal and local government responses create tax presence and residency issues for businesses and individuals. Tax professionals and advisers must have a solid understanding of the relevant rules for nonresident aliens and non-U.S. businesses and their interplay with recent Treasury and IRS guidance in light of the coronavirus pandemic.

On Apr. 21, 2020, in response to COVID-19 and travel and other disruptions, Treasury and the IRS provided guidance, specifically Rev. Proc. 2020-20 and Rev. Proc. 2020-27, along with “Frequently Asked Questions” issued by the IRS, to mitigate potential negative tax consequences for individuals and businesses, including with respect to residency, the foreign income exclusion, and U.S. trade or business and permanent establishment issues.

Listen as our panel guides tax professionals and advisers in determining taxpayer status for non-U.S. citizens and businesses, challenges for U.S. citizens currently working abroad, reporting requirements and available mechanisms in light of recent IRS guidance, and best practices for taxpayers.

Outline

  1. Tax presence and residency issues created by COVID-19
  2. Tax issues for non-U.S. individuals and businesses
  3. Tax issues for U.S. citizens forced to stay abroad
  4. Compliance and reporting challenges for taxpayers

Benefits

The panel will review these and other key issues:

  • What is the impact of COVID-19 on the tax presence and residency of individuals and businesses?
  • How does Rev. Proc. 2020-20 impact the application of the "substantial presence test"?
  • How does Rev. Proc. 2020-27 impact the foreign earned income exclusion?
  • How do IRS “Frequently Asked Questions” impact the determination of whether a business is considered to have a U.S. trade or business or permanent establishment?
  • How should taxpayers document positions and anticipate future audits?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the impact of COVID-19 on the tax presence and residency of individuals and businesses
  • Identify key provisions and issues associated with recently issued Rev. Proc. 2020-20 and Rev. Proc. 2020-27
  • Recognize allocation issues associated with U.S. and non-U.S. businesses with employees working away from their home jurisdiction
  • Ascertain methods for managing potential nonresident audits and overcoming other regulatory, reporting, and compliance challenges

  • 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. Specific knowledge and understanding of partnership tax rules, corporate structure, and state audit and tax regulations.

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).