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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

    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.

$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
    1. Lien process
    2. Levy
    3. Asset seizures
  2. Interplay of U.S. tax treaties and IRS collections
  3. Challenging liens
    1. Claiming IRS issued lien in error
    2. Appealing a lien filing under IRS Section 6320
    3. 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?