BarbriSFCourseDetails
  1. keyboard_arrow_leftBack

Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Wednesday, May 11, 2022

  • 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 course will provide tax counsel and advisers an in-depth analysis of effective methods and challenges in resolving international tax compliance issues and disputes. The panel will discuss critical tax compliance issues stemming from Forms 3520/3520-A and 5471, navigating FBAR assessments and litigation, the evolution of the "non-willful" standard, and managing administrative appeals, federal district court, and U.S. Court of Federal Claims litigation.

Faculty

James Cassidy
International Advisor
Schulman Lobel, LLP

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.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Parag P. Patel
Attorney
Patel Law Offices

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.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Justin Donatello
Principal
KPMG Law, LLP

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.


 

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

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.

Outline

  1. International tax compliance
    • Form 3520/3520-A
    • Form 5471
    • Penalties
  2. Managing audits and IRS examinations
  3. FBAR controversy
    • Administrative appeals
    • District court and U.S. Court of Federal Claims litigation
    • Evolution of IRS "non-willful" standard
  4. Best practices for tax counsel

Benefits

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?

NASBA Details

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.

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).