About the Course
Introduction
This webinar will examine the international tax positions, reporting failures, and compliance issues most likely to attract IRS examination scrutiny. Our panel of seasoned tax professionals will discuss current international audit priorities, common audit triggers, and practical strategies for identifying and mitigating risk for multinational taxpayers.
Description
The IRS continues to devote significant enforcement resources to international compliance matters, making some reporting and tax positions particularly vulnerable to examination. Certain international tax positions have historically attracted IRS attention and often serve as gateways to broader examinations; for example, specified foreign financial assets reported on Form 8938, FBAR compliance failures, FIRPTA reporting and withholding for nonresident aliens, and transfer pricing positions involving related-party transactions consistently draw scrutiny. Taxpayers and advisers must understand not only these substantive risk areas but also the tools and techniques IRS examiners use to identify reporting discrepancies, uncover foreign assets, and expand the scope of international examinations.
Listen as our accomplished panel of international tax attorneys discusses the international tax positions most likely to trigger IRS scrutiny, outlines practical approaches to reducing examination risk, and provides guidance for defending common international reporting and compliance positions during an audit.
Presented By
Ms. Gozlan is a Senior Associate at Lippes Mathias, where she advises high-net-worth individuals, families, family offices, estates, and closely held businesses on complex domestic and international tax matters. Her practice includes representing clients before the IRS in examinations, collection matters, refund claims, and other tax disputes, while also advising on estate and gift tax matters, business succession planning, and tax-sensitive strategies for closely held businesses and their owners. Ms. Gozlan works closely with clients, accountants, wealth advisors, and other professionals to identify and address tax issues arising from significant wealth, business, and life transitions. Before joining Lippes Mathias, she served as an Attorney with the Internal Revenue Service’s Office of Chief Counsel in the Large Business & International Division, where she advised examination teams in the Global High Wealth and Large Partnership practices. Ms. Gozlan's government experience includes complex partnership and cross-border tax matters, sophisticated tax structures, and examinations of high-net-worth taxpayers and closely held businesses, giving her a unique perspective on how the IRS approaches complex tax planning, compliance, and enforcement.
Mr. Rowe focuses his practice primarily on Tax Controversy and Audit Defense, assisting clients with federal income tax issues and federal gratuitous transfer tax issues. Before joining Lippes Mathias, he worked for the Internal Revenue Service’s Office of Chief Counsel in the Large Business and International Tax Division. While with the Office of Chief Counsel, Mr. Rowe represented the IRS in Tax Court and assisted IRS examinations of large businesses and high net worth individuals, with a focus on international (including transfer pricing), large partnership, corporate, private equity, real estate, cannabis, and micro-captive insurance related tax issues.
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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).
Date + Time
- event
Monday, December 7, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. International tax audit environment
II. Form 8938 reporting risks
III. FBAR compliance and enforcement
IV. FIRPTA reporting for nonresident aliens
V. Transfer pricing scrutiny
VI. Offshore digital assets
VII. Aggressive treaty positions
VIII. Puerto Rico residency and source-of-income positions
IX. IRS international audit tools and techniques
X. Practical strategies for minimizing international audit risk
The panel will cover these and other critical issues:
- FBAR compliance, penalty exposure, and overlap with FATCA reporting
- Treaty-based return positions and disclosure requirements
- Puerto Rico residency and source-of-income audit challenges
- Transfer pricing documentation and audit exposure
- Reporting considerations for digital assets held in offshore accounts
Learning Objectives
After completing this course, participants will be able to:
- Determine FIRPTA compliance issues for NRA real property transactions
- Ascertain documentation standards for transfer pricing arrangements
- Recognize reporting risks associated with offshore-held digital assets
- Identify audit triggers related to treaty-based return positions
- Decide on practical strategies to reduce international audit exposure
- 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/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, 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.
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 Barbri-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 .
