International Tax Compliance: Navigating Tax Implications of Cross-Border Activities
Reporting and Filing Requirements, Guidelines on IRS Issue-Based Examinations, Audits and Litigation
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This course will provide tax counsel and advisers with a practical discussion of the tax implications, reporting requirements of cross-border activities, and issue-based examinations of foreign activities of individuals and companies. The panel will review complex international tax issues associated with cross-border transactions, navigating the compliance and reporting obligations, and guide advisers on how to avoid the assessment of penalties, additional tax liability and potential audits.
Outline
- Tax reform impact on cross-border activities
- IRS protocol for issue-based examinations and guidelines for counsel
- Reporting standards and methods to avoid penalties, additional tax liability and ensure compliance
- Strategies for handling FBAR audits, opt-outs, appeals and litigation
Benefits
The panel will review these and other key concepts:
- Reporting requirements and methods for offshore compliance
- An overview of the implications of tax reform on cross-border activities
- Tactics in handling IRS issue-based examinations
- Appealing penalty assessments, handling audits and litigation tactics
Faculty
Alison N. Dougherty, J.D., LL.M., CPA
Partner
Aronson
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.
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Antoinette L. Ellison, J.D., LL.M.
Counsel
Jones Day
Ms. Ellison focuses her practice on the resolution of federal and state tax controversy matters. She has extensive... | Read More
Ms. Ellison focuses her practice on the resolution of federal and state tax controversy matters. She has extensive experience handling every stage of a tax controversy, including all administrative and judicial levels from examination through litigation. Her experience includes trials in proceedings before the United States Tax Court and U.S. district courts. She also has resolved numerous administrative appeals. She represents a broad range of clients, including individuals, privately held businesses, and large publicly traded companies.
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