Withholding Tax on Cross-Border Transactions Under Heightened IRS Scrutiny
Strategies to Improve Compliance and Minimize Audit Risks
Recording of a 100-minute CLE/CPE teleconference with Q&A
Conducted on Wednesday, June 24, 2009
Recorded event now available
This seminar will identify the more complex U.S. withholding obligations on cross-border transactions, explain the heightened IRS oversight in this area, and present best practices for improving compliance and preparing for audits.
Description
The IRS is significantly ramping up enforcement of required withholding of tax from cross-border business transactions. How significantly? Proper reporting and withholding of U.S.-sourced fixed, determinable, annual or periodic (FDAP) income was elevated to Tier 1, the IRS' highest priority.
Form 1042 and 1042-S filers must anticipate where the new IRS audit teams will focus as they scrutinize payments to foreign entities and individuals. A new Internal Revenue Service Manual provision reveals its targeted interest in certain industries and specific payments like original issue discounts.
A proactive approach to improving withholding compliance on cross-border payments and to planning your company's positions in withholding audits will go a long way toward ensuring proper compliance and avoiding interest and penalties.
Listen as our expert panel analyzes the cross-border withholding challenges and the associated IRS enforcement initiative and offers alternatives for remedial actions and advance planning.
Outline
- Overview of IRS Actions in Cross-Border Withholding Enforcement
- IRS Voluntary Compliance Program (VCP)
- IRM audit manual provisions
- Withholding tax elevated to Tier I level
- Best Practices to Improve Compliance and Minimize Audit Risks
- Detailed review of current withholding practices
- Remedial measures to correct deficiencies
- Use IRM audit guidelines to conduct internal audit
- Experience of participants in VCP
- Preparing for an IRS audit
- Potential Changes in Withholding Transactions
- Qualified intermediaries
- Obama’s proposals for withholding agents
Benefits
The panel will review these and other key questions:
- What industries are primary targets of the IRS audit initiatives?
- What transactions will be given heightened scrutiny in an audit?
- Why is the IRS focusing heavily on audits of financial institutions' withholding?
- What information and documentation will companies need to produce in an audit to justify compliance with their withholding obligations?
Faculty
Cyrus Daftary,
Partner
Burt Staples & Maner, Washington, D.C.
He specializes in international taxation and regulatory compliance. He has extensive experience with the United States withholding and reporting rules for U.S. and non-U.S. persons, as well as the U.S. Patriot Act and various anti-money laundering regimes, the European Savings Directive, and e-commerce issues.
Laurie Hatten-Boyd,
Partner
KPMG, Seattle
She is a Principal in KPMG’s Information Reporting Practice and specializes in cross-border withholding and reporting issues. Prior to KPMG, she was with the IRS Office of Associate Chief Counsel where she worked with the section 1441 withholding regime, including co-drafting amendments to the 1441 regulations, the qualified intermediary agreement and qualified intermediary audit guidelines.
Ordering
Online Webinar
Includes audio streaming of full program plus handouts (available 24 hours after live seminar).
CPE: Self-study CPE is not offered on online webinars.
Online Seminar Audio $247.00
Available 24 hours after the live event
Recorded Event
Includes full event recording plus handouts (available after live seminar).
CPE: Self-study CPE is not offered on recorded events.
CLE: Pre-approved for self-study credit in: AK, AZ, CA, CT, HI, MO, MT, NY, TX, VT, WA, WV. Upon request, self-study credit is also available in: CO, FL, GA, ID, KY, ME, ND, NE, NH, NM, NV, OR, UT, WI, WY. If you are applying for self-study credit in one of these states, contact Strafford CLE at 1-800-926-7926 ext. 35 or CLE@straffordpub.com.
MP3 Download (Audio Only) $247.00
Available 24 hours after the live event
CD $247.00
plus $9.45 S&H
Available ten business days after the live event
NASBA CPE Sponsor
Strafford 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 credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417 or by visiting www.nasba.org.
CPE Credit
Strafford is a NASBA CPE sponsor and our live seminars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.
CLE Credit
Strafford's live seminars qualify for CLE in every state that accredits webinars. They offer you a high quality, cost effective, and convenient CLE option, with no lost travel time or expenses.
Customer Reviews
It was an excellent program!!
Marni Odermann
Supervalue
This teleconference greatly helped us understand the new challenges.
Andrew Toth
Tronconi Segarra & Associates
The program had excellent presenters that were extremely knowledgeable.
Lisa R. Volland
Legacy Professionals
I liked that the program went beyond the guidance in the regs to offer a real-world perspective.
Jerry Bourlier
Yazaki Management Co.
Coverage was practical and straightforward. Well done.
Stuart J. Frentz
Bradley Arant Boult Cummings
Federal Income Tax Advisory Board
David Bowen
Principal
Grant Thornton
Joseph Calianno
Partner, National Tax Practice
Grant Thornton
George Manousos
Partner
PricewaterhouseCoopers
Federal Tax Partner
Nixon Peabody
Tax Controversy Partner
Crowell & Moring
Tax Controversy Partner
Latham & Watkins
Tom Windram
Managing Director & National Leader, Federal Tax Credits & Incentives
RSM McGladrey