New IRS Foreign Compliance Initiatives: FATCA Accuracy Exams, Offshore Service Providers, 1120F Waiver Processes
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide corporate tax professionals with a practical guide to three recently announced IRS LB&I international compliance initiatives that will impact U.S. corporations with offshore holdings. The panel will discuss the IRS enhanced focus on offshore service providers, the FATCA accuracy initiative, and the new waiver processes for Form 1120F Delinquencies.
- Prior LB&I Division foreign reporting compliance campaigns announced in 2018
- Offshore service providers and potential for abuse and asset nondisclosure
- FATCA accuracy initiative
- Form 1120-F delinquency and waiver request changes
- Filing a delinquent Form 1120-F voluntarily when the taxpayer reports without an IRS examination
- Proceeding with filing waiver request in cases where an IRS examination of the taxpayer reveals noncompliance
- Factors considered in the Form 1120-F waiver summary analysis
The panel will discuss these and other important topics:&
- Identifying what constitutes an impermissible use of an "abusive tax scheme" by an offshore service provider, and what measures the LB&I Division may use to discover abuses by these providers
- What tools might the IRS employ in its FATCA accuracy initiative?
- The specific changes to the 1120-F delinquent submittal and waiver request submission process under the new guidance
Colvin & Hallett
Mr. Colvin's practice emphasizes federal tax controversies and white-collar criminal defense. He is a frequent... | Read More
Mr. Colvin's practice emphasizes federal tax controversies and white-collar criminal defense. He is a frequent speaker on tax topics and chairs the ABA Taxation Section's Subcommittee for Legislative and Administrative Developments.Close
Matthew D. Lee
Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white... | Read More
Mr. Lee is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense, federal tax controversies, financial institution regulatory compliance, and complex civil litigation. He has significant experience in conducting corporate internal investigations and advising banks and financial institutions as to compliance issues involving FATCA, the Bank Secrecy Act, the USA Patriot Act, anti-money laundering laws and regulations, and economic sanctions. He also represents financial institutions in enforcement proceedings brought by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN).Close
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