International Tax Eggshell Audits and Recent IRS Enforcement: Assessing Audit Risk for U.S. Residents and Nonresidents
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will update international tax advisers on the IRS' current campaign targeting foreign taxpayers and foreign income. Our astute panelist will discuss the IRS' current enforcement actions, outline managing an IRS examination, and highlight offshore voluntary compliance options.
Outline
- Update on IRS enforcement
- IRS examination approach
- Common examples of eggshell audits
- Assessing risk for income tax returns of residents
- Assessing risk for income tax returns of nonresidents
- IR 2023-166: high income, high net worth, non-filer initiatives
- Other examination areas
- Offshore voluntary disclosure
- What's next?
Benefits
The panelist will cover these and other critical issues:
- The current state of IRS examinations of international taxpayers
- Targeted examination areas for multinational taxpayers
- Assessing audit risk for income tax returns for residents and nonresidents
- Examples of common issues that generate eggshell audits
- How the IRS uses the DIF score and data analytics in the audit selection process
Faculty
Mishkin Santa, JD, LLM, TEP
Principal, Director of International Tax
The Wolf Group
Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift &... | Read More
Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift & trust tax compliance, FBAR Assistance, foreign trust tax compliance, exit tax planning, EB-5 investor program, international assignment structuring and planning, offshore voluntary disclosure programs, foreign corporation (Subpart F, Transfer Pricing, E&P Studies), and asset protection planning. His client base includes U.S. citizens living overseas, U.S. nonresidents, EB-5 investors, U.S. domestic individuals and families, international businesses, international based families with investments in multiple jurisdictions and tax residency in multiple jurisdictions, U.S. citizens or residents who are beneficiaries of foreign trusts and who will receive gifts or inheritances from non-US persons, and trustees of trusts with U.S. grantors or U.S. beneficiaries.
