IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will discuss IRS examinations of taxpayers living abroad. Our expert panel will guide tax practitioners through the examination process and explain best practices to withstand the on-going scrutiny of these taxpayers' returns.
Outline
- Expatriates: introduction
- Common expat audit issues
- Non-filers
- Filing status
- Unreported capital gains
- Information reporting returns
- Unallowed business deductions
- Other areas
- Latest IRS expat compliance campaigns
- Section 965 transition payments
- Exit taxes and unsubmitted Forms 8854
- Examination process
- Best practices
Benefits
The panel will cover these and other critical issues:
- Which expatriate returns are being targeted by the IRS?
- How to best handle unfiled returns, including FBAR filings
- When should a taxpayer consider an appeal?
- What additional issues are being reviewed during Section 965 examinations?
- How can expats and tax advisers best prepare for IRS examinations?
Faculty
Thomas M. Giordano-Lascari
Partner
Greenberg Glusker Fields Claman & Machtinger
Mr. Giordano-Lascari is a Partner in the Private Client Services Group with nearly two decades of experience... | Read More
Mr. Giordano-Lascari is a Partner in the Private Client Services Group with nearly two decades of experience in advising high-net-worth individuals and closely-held businesses with international income tax and estate planning issues.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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Steven (Steve) Toscher
Managing Principal
Hochman Salkin Toscher Perez
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions... | Read More
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.
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