About the Course
Introduction
This webinar will provide a comprehensive analysis of U.S. tax and reporting requirements for taxpayers with beneficial interests in foreign retirement accounts, including pensions, annuities, and foreign social security-type arrangements. The panel will examine how recent proposed regulations released in May 2024 reshape the classification and reporting treatment of foreign retirement and savings vehicles.
Description
U.S. taxpayers with foreign retirement interests—including expatriates, inbound taxpayers, and globally mobile employees—face complex and often inconsistent tax treatment. Many foreign plans do not qualify for deferral under IRC Section 401, creating current income inclusion risks and potential double taxation. Practitioners must also evaluate when foreign arrangements are treated as grantor trusts, employee benefit plans, or investment accounts under U.S. tax law.
Recent proposed regulations significantly expand the framework established under Rev. Proc. 2020-17 by broadening the definition of "tax-favored foreign retirement trusts." These changes directly affect whether certain plans are exempt from Form 3520 reporting and alter determinations of filing thresholds, eligibility for relief, and classification of foreign pensions. Deciding whether to rely on the proposed regulations is a critical determination for pensioners and their advisers.
Listen as our panel of international tax practitioners provides detailed guidance on navigating the classification, taxation, and reporting of foreign retirement accounts, with practical examples illustrating common compliance pitfalls and strategies to mitigate reporting exposure.
Presented By
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.
Ms. Lor assists families and individuals with cross-border interests manage their assets and businesses efficiently from a tax perspective. With over 13 years of experience at the IRS, she also brings extensive expertise in tax controversy, offering strategic guidance for complex tax challenges.
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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
Thursday, August 20, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Classifications of foreign pensions, annuities, and social security
II. Income calculations: distributions and ownership
III. Differentiation between most foreign plans and U.S.-qualified plans
IV. 2024 Proposed Regulations
V. Informational reporting: FBAR, FATCA, Forms 3520/3520-A
VI. Case studies and practical applications
The panel will discuss these and other critical topics:
- How the proposed regulations modify Revenue Procedure 20-17
- What are the reporting requirements for U.S. taxpayers participating in foreign retirement accounts?
- What are the tax consequences for U.S. taxpayers when employers contribute to foreign retirement accounts?
- What is the tax impact of distributions from foreign retirement accounts for U.S. taxpayers, whether they reside in another country or the U.S.?
- Thresholds and contribution limits under the proposed regulations
Learning Objectives
After completing this course, you will be able to:
- Ascertain the reporting requirements for U.S. taxpayers participating in foreign retirement accounts
- Differentiate between most foreign plans and U.S. "qualified plans"
- Select which IRS forms are necessary to fulfill obligations to report foreign financial assets and interests with both the IRS and FinCEN
- Recognize tax provisions, including deferral provisions, in relevant tax treaties
- Recognize the interaction of Forms 8938, 3520, and FBARs
- 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 for U.S. taxpayers owning or receiving payments from non-US retirement accounts; supervisory authority over other preparers/accountants. Specific knowledge and understanding of basic reporting requirements for U.S. taxpayers with foreign retirement account interests; familiarity with FBAR, FATCA and For 3520 filings
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 .
