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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 video webinar with Q&A

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Conducted on Wednesday, May 11, 2022

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course 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 the 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, and district court and court of federal claims litigation?
  • What are the key issues and requirements of the IRS "non-willful" standard?

Faculty

Cassidy, Jim
James (Jim) Cassidy, CPA

International Advisor
Schulman Lobel

Mr. Cassidy is a Certified Public Accountant (New York) with more than 30 years of experience providing U.S. and...  |  Read More

Donatello, Justin
Justin Donatello

Managing Director
KPMG

Mr. Donatello is a Managing Director in the KPMG Washington National Tax (“WNT”) Tax Controversy and...  |  Read More

Patel, Parag
Parag P. Patel, Esq.

Attorney
Patel Law Offices

Mr. Patel’s practice concentrates on tax, international tax planning, estate planning, and elder law. His focus...  |  Read More

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