Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471

Evolution of "Non-Willful" Standard, Identifying Compliance Issues, District Court and Court of Federal Claims Litigation

Recording of a 90-minute premium CLE/CPE webinar with Q&A


Conducted on Thursday, April 30, 2020

Recorded event now available

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Program Materials

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of effective methods and challenges in resolving international tax compliance issues and disputes. The panel will discuss critical tax compliance issues stemming from Forms 3520/3520-A and 5471, navigating FBAR assessments and litigation, the evolution of the "non-willful" standard, and managing administrative appeals, federal district court, and U.S. Court of Federal Claims litigation.

Description

Cross-border tax audits are expanding dramatically, and the resulting tax assessments are problematic for U.S. multinational companies and their stakeholders. Areas of controversy such as transfer pricing and permanent establishments, in addition to reporting and filing issues, remain a high priority for IRS examinations and audits.

Taxpayers with international tax reporting obligations suffer from rigorous compliance and enforcement efforts and overly complicated rules and regulations. The IRS is increasingly more effective at identifying noncompliant taxpayers. Possessing an in-depth understanding of international tax rules and regulations will assist counsel and tax advisers in helping taxpayers maintain compliance and avoid IRS examination. A taxpayer's failure to properly adhere to reporting and filing requirements associated with cross-border activities and foreign assets can result in severe civil and criminal penalties.

Grasping a complete understanding of challenges associated with Forms 3520/3520-A and 5471, the IRS "non-willful" standard, and navigating the appeals process, are essential to assess and manage international tax compliance disputes thoroughly.

Listen as our panel explains the most complex aspects of international tax compliance, including FBAR filing and reporting requirements, navigating assessments and litigation, the evolution of the "non-willful" standard, and managing administrative appeals, the federal district court, and U.S. Court of Federal Claims litigation.

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Outline

  1. International tax compliance
    1. Form 3520/3520-A
    2. Form 5471
    3. Penalties
  2. Managing audits and IRS examinations
  3. FBAR controversy
    1. Administrative appeals
    2. District court and U.S. Court of Federal Claims litigation
    3. Evolution of IRS "non-willful" standard
  4. Best practices for tax counsel

Benefits

The panel will review these and other key issues:

  • What are the international tax compliance issues and pitfalls to avoid?
  • What are the critical issues stemming from Forms 3520/3520-A and 5471?
  • How can you minimize risks of audits?
  • What are the key challenges of FBAR controversies, administrative appeals, district court and court of federal claims litigation?
  • What are the key issues and requirements of the IRS "non-willful" standard?

Faculty

Stein, Michel
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

Toscher, Steven
Steven (Steve) Toscher

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

Other Formats
— Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video

$347

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CPE Not Available

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