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
CPE on Live Event
Continuing Professional Education credit processing is available for an additional $35 per person. You may register for CPE credit processing at any time before or after the program.
Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a CPE sponsor.
CPE Processing $35.00
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*, MO, MT, NY*, TX, VT, WA. Upon request, self-study credit is also available in: CO, FL, GA, ID, KY, LA, ME, ND, NE, NH, NM, NV, OR, UT, WI, WV, 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. (*For CT and NY, Strafford needs to process the CLE — see below to purchase this option.)
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
CLE on CD Processing $65.00
CPE Credit
Strafford's 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
Great preparatory material. Conference helped to highlight some of the points that I need to consider going forward.
Rick Campbell
Corptax
This teleconference greatly helped us understand the new challenges.
Andrew Toth
Tronconi Segarra & Associates
Very interesting, informed us on the most recent updates.
Kristin Thompson
Global Tax Management
I liked that the program went beyond the guidance in the regs to offer a real-world perspective.
Jerry Bourlier
Yazaki Management Co.
The program had excellent presenters that were extremely knowledgeable.
Lisa R. Volland
Legacy Professionals
Federal Income Tax Advisory Board
David Bowen
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Joseph Calianno
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George Manousos
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Nixon Peabody
Tax Controversy Partner
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Tax Controversy Partner
Latham & Watkins
Tom Windram
Managing Director & National Leader, Federal Tax Credits & Incentives
RSM McGladrey