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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, May 27, 2025

  • 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
CLE
CPE
ALL

This CLE/CPE webinar will provide tax professionals with a comprehensive and practical guide to navigating the process of responding to and challenging IRS collection actions, specifically as it relates to seizures of foreign assets and accounts. The panelist will discuss IRS procedures, detailing the stages of IRS collection activity and the application of tax treaties, as well as provide useful tools for challenging or delaying the collection proceedings. The webinar will also offer guidance on the formal appeals process, including the impact of recent IRS final regulations and bases for appeal, and useful tools for compiling and submitting the appeal correspondence and documentation.

Faculty

Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Description

One of the most frightening events for taxpayers is receiving an IRS notice indicating that the Service is pursuing an enforced collection action, which may also cause a taxpayer's foreign assets and accounts to be subject to IRS seizure. Generally, taxpayers are not aware of the IRS' reach when it comes to foreign assets. Tax counsel must accordingly have an advanced understanding of the IRS' enforced collection process to effectively defend taxpayers who find their foreign assets subject to lien, levy, and seizure.

The key statutory tools available to the IRS in collecting alleged tax deficiencies are lien, levy, and asset seizure powers. Each of these actions has a defined course of escalating notice and response requirements. In addition, U.S. tax treaties with jurisdictions where such assets are held or located may allow IRS access to these assets. Depending on the nature of the tax due and the stage of the collection process, tax counsel has available defense and mitigation remedies for each collection action.

Knowing what tools are available to challenge IRS-enforced collections enables tax counsel to properly respond to IRS actions.

Listen as Patrick J. McCormick, J.D., LL.M., Partner at Rimon Law, provides a thorough, "beyond-the-basics" guide to effectively navigating the IRS' collection process once foreign asset attachment or seizure is on the table as an option for collecting delinquent tax.

Outline

  1. IRS-enforced collection process
    • Lien process
    • Levy
    • Asset seizures
  2. Interplay of U.S. tax treaties and IRS collections
  3. Challenging liens
    • Claiming IRS issued lien in error
    • Appealing a lien filing under IRS Section 6320
    • Obtaining partial or full discharge of lien
  4. Challenging and defending against levy action
  5. Assets exempt from levy

Benefits

The panelist will review these and other key issues:

  • What are the applicable tax rules that allow the IRS to attach foreign assets and accounts in collections?
  • How is the interplay between U.S. tax treaties and IRS collections?
  • What is the correspondence chain leading up to enforced collection action by the IRS?
  • What are the remedies and relief provisions to challenge or mitigate a tax lien?
  • What are the bases of challenging tax levies and asset seizures?
  • What protections or tactics are available to taxpayers regarding foreign assets and accounts?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the escalation pattern of IRS notices leading up to enforced collection actions
  • Decide on strategies in responding to IRS Notice of Intent to Levy
  • Discern options for negotiating with IRS during collection process
  • Identify available challenges to IRS lien and levy actions

  • 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, law or public firm experience at mid-level within the organization, handling tax matters for businesses and high net worth individuals; supervisory authority over other attorneys, preparers, accountants. Knowledge and understanding of IRS Enforced Collection Process, including the liens, levies and asset seizures. Familiarity with defending taxpayers in IRS audits, investigations and procedures.

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).