New Webinar: Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471

I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471” scheduled for Wednesday, May 11, 2022 1:00pm-2:30pm EDT. 

The IRS has continually reaffirmed its commitment to cracking down on U.S. taxpayers failing to disclose reportable foreign assets. The IRS is intensifying audits for foreign disclosures, and tax advisers need to act quickly to take advantage of the benefits that may apply to their situations. Our panel will provide counsel and tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets and assisting clients with developing programs that provide workable solutions.

After our presentations, we will engage in a live question and answer session with participants so we can answer questions about these important issues directly. A description of the webinar is below.

Our office has 5 FREE registrations. Please email us to receive one!

To pay and register click this link for more information: https://www.sp-04.com/r.php?products/tlixfdhgra

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.

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
    1. Form 3520/3520-A
    2. Form 5471
    3. Penalties
  2. Managing audits and IRS examinations
  3. FBAR controversy
    1. Administrative appeals
    2. District court and U.S. Court of Federal Claims litigation
    3. 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?

Our office has 5 FREE registrations. Please email us to receive one!

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