Description
Cross-border tax audits are expanding dramatically, and the resulting tax assessments are problematic for U.S. multinational companies and their stakeholders. Areas of controversy such as transfer pricing and permanent establishments, in addition to reporting and filing issues, remain a high priority for IRS examinations and audits.
Taxpayers with international tax reporting obligations suffer from rigorous compliance and enforcement efforts and overly complicated rules and regulations. The IRS is increasingly more effective at identifying noncompliant taxpayers. 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.
Grasping a complete understanding of the challenges associated with Forms 3520/3520-A and 5471, the IRS "non-willful" standard, and navigating the appeals process, are essential to assess and manage international tax compliance disputes thoroughly.
Listen as our panel explains the most complex aspects of international tax compliance, including FBAR filing and reporting requirements, navigating assessments and litigation, the evolution of the "non-willful" standard, and managing administrative appeals, the federal district court, and U.S. Court of Federal Claims litigation.
Presented By
Mr. Cassidy is a Certified Public Accountant (New York) with more than 30 years of experience providing U.S. and international individual tax consulting and compliance services to international assignee executives, high net-worth individuals, investors as well as athletes & entertainers. He gained most of his experience working for some of the largest accounting public accounting firms, such as PwC, and recently with BDO as the U.S. National Tax Technical Leader for expatriate tax services. He spent several years living in Mexico City and Toronto, assisting clients with local and U.S. tax advice.
Mr. Donatello is a Managing Director in the KPMG Washington National Tax (“WNT”) Tax Controversy and Dispute Resolution Services practice, which represents firm clients at all levels of controversy before the IRS. The practice represents clients at the examination and appeals level, using both traditional resolution methods and various alternative dispute resolution techniques such as mediation.
Mr. Patel’s practice concentrates on tax, international tax planning, estate planning, and elder law. His focus is on all tax matters including international tax law, foreign bank account disclosures, tax audit defense, and tax appeals. He has advocated over one hundred voluntary tax disclosures for assets before the US Internal Revenue Service. He is a frequent speaker and writer on legal issues affecting tax, foreign account planning, and estate planning.
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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 90-minute webinar is accredited for 1.5 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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Date + Time
- event
Wednesday, May 11, 2022
- schedule
1:00 p.m. ET./10:00 a.m. PT
- International tax compliance
- Form 3520/3520-A
- Form 5471
- Penalties
- Managing audits and IRS examinations
- FBAR controversy
- Administrative appeals
- District court and U.S. Court of Federal Claims litigation
- Evolution of IRS "non-willful" standard
- Best practices for tax counsel
The panel will review these and other key issues:
- What are the international tax compliance issues and pitfalls to avoid?
- What are the critical issues stemming from Forms 3520/3520-A and 5471?
- How can you minimize risks of audits?
- What are the key challenges of FBAR controversies, administrative appeals, and district court and court of federal claims litigation?
- What are the key issues and requirements of the IRS "non-willful" standard?
Learning Objectives
After completing this course, you will be able to:
- Identify key international tax compliance issues for multinational companies
- Recognize key issues and acquire effective methods in completing Form 3520/3520-A and Form 5471
- Ascertain methods to minimize IRS audits stemming from international tax compliance
- 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, supervising other attorneys or accountants. Specific knowledge and understanding of foreign asset information reporting requirements, particularly FATCA and FBAR/FinCen 114; familiarity with IRS audit procedures in examining foreign tax reporting, familiarity with voluntary disclosure programs.
BARBRI 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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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