This CLE/CPE course will provide tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel will discuss new and significant changes to international taxation relating to the disposition of U.S. partnership interests owne... Read More

This CLE/CPE webinar will provide tax professionals with a comprehensive and practical guide to navigating the process of responding to and challenging IRS collection actions, specifically as it relates to seizures of foreign assets and accounts. The panelist will discuss IRS procedures, detailing t... Read More

This course will provide tax advisers, professionals, and preparers with a solid overview and explanation of key income tax treaty provisions needed to determine whether their clients may take treaty-based return positions. The panel will discuss income tax treaties that exist between the U.S. and o... Read More

This webinar will analyze the rules for determining U.S. shareholder and controlled foreign corporation (CFC) status, including determining direct, indirect, and constructive ownership. Our panel of knowledgeable global tax veterans will provide real world examples that walk international practition... Read More

This webinar will discuss the information and income tax reporting obligations for individuals and businesses owning cryptocurrency. Our panel of foreign tax veterans will discuss the diverse treatment of digital assets in the U.S. and abroad, provide insights and advice on meeting tax and disclosur... Read More

This CLE/CPE course will provide tax attorneys and accountants with a detailed discussion of best practices for requesting relief from IRS penalties as a result of failing to timely file required international information forms such as Forms 5471, 5472, 3520, 3520-8858, 8865, 926, and the FBAR. The... Read More

This CLE/CPE course will provide tax counsel with a thorough and practical guide to structuring alternatives and tax considerations for foreign investors in U.S. real estate. The panel will outline best practices for determining the purchasing entity and review tax planning opportunities in structur... Read More

This CLE/CPE course will provide tax counsel and ERISA attorneys a detailed analysis of the tax rules governing foreign pension accounts, with a specific focus on avoiding penalties for noncompliance. The webinar will go beyond the basics to offer useful practice pointers on the application of IRC 4... Read More

This webinar will identify the most frequent foreign entity structures encountered by U.S. international tax practitioners and their U.S. reporting requirements. Our panel of astute foreign tax professionals will divulge how these structures correspond with U.S. entity reporting structures, how they... Read More

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of key tax planning techniques and challenges for real estate investors. The panel will discuss strategies for key tax planning considerations for the acquisition, ownership and ultimate disposition of real estate. D... Read More

This CLE/CPE course will provide tax counsel and compliance professionals guidance on the rules, reporting requirements, and available tax planning mechanisms for U.S. nonresident alien taxpayers. The panel will offer approaches for determining taxpayer classification, identifying and reporting inco... Read More

This CLE/CPE webinar will provide tax professionals guidance on required foreign reporting obligations, best practices for avoiding penalties, and how to resolve past noncompliance for trusts and estates. The panel will discuss the potential impact of the SCOTUS ruling in Loper Bright, FATCA and FBA... Read More

This CLE/CPE webinar will provide tax counsel and advisers guidance on recent developments in U.S. international taxation and related IRS guidance for foreign activities of individuals and companies. The panel will review complex international tax issues associated with cross-border activities and t... Read More

This CLE/CPE webinar will provide tax counsel guidance on the U.S. tax treatment of foreign rental income and international real estate investments. The panel will discuss U.S. sourcing of income rules, exemptions, and reporting requirements. The panel will also provide insights into typical structu... Read More

This CLE/CPE webinar will provide tax professionals with an in-depth analysis of the net investment income tax (NIIT) relief under current U.S. tax law and the interplay with income tax treaties. The panel will discuss the recent court ruling in Christensen v. United States and the IRS' appeal of su... Read More

This webinar will take a comprehensive look at the limitation on benefits (LOB) provisions in U.S. income tax treaties. Our panel of prominent international tax attorneys will review the purpose of LOB clauses in these treaties and discuss meeting residency requirements using the U.S. Model Treaty a... Read More

This course will discuss the complications surrounding the determination of foreign earnings and profits (E&P) for controlled foreign corporations (CFCs). Our panel of foreign tax experts will discuss the complexities of the related calculations, including categorizing income, handling retroactive a... Read More

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and nonresidential rentals, and properly reporting rental income and expenses with a... Read More

This CLE/CPE webinar will provide estate planners with a comprehensive guide to tax planning challenges and opportunities for clients who have a tax presence in both the U.S. and Australia. The panel will discuss the U.S. tax law and treaty provisions that govern tax and fiduciary rules in both Aust... Read More

This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of the tax and operational impacts of foreign entity selection for individuals owning controlling interests in international businesses. The panelist will discuss the tax issues that arise in foreign entity selection, wit... Read More

This webinar will discuss the application of the saving clause in U.S. international income tax treaties. Our panel of foreign tax matter experts will identify the saving clause in U.S. income tax treaties, analyze saving clause exceptions, and provide examples of the application of the saving claus... Read More

This course will provide tax practitioners working with U.S. nonresident aliens (NRAs) with practical steps to minimize U.S. taxes for these U.S. taxpayers. The panelists will cover the rules for federal income, estate, and gift taxation of nonresidents and provide concrete advice on mitigating thes... Read More

This CLE/CPE webinar will provide tax advisers with guidance on the advantages and pitfalls of using the "check the box" election for foreign LLCs and disregarded entities. The panel will discuss the tax impact of specific elections of income from foreign disregarded entities and outline tax timing... Read More

This webinar will explain the transfer taxes paid in Canada and the U.S. by residents of the U.S. and/or Canada. Our panel of foreign tax experts will discuss specific articles in the Canada-U.S. Income Tax Treaty and provide examples of how these can be applied to mitigate estate and gift taxes pai... Read More

This CLE/CPE course will provide tax counsel and advisers with a detailed guide to preparing and filing a foreign financial institution (FFI) agreement. The panel will describe the FFI designation in depth, outline the due diligence and reporting requirements of a participating FFI, and discuss the... Read More