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
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.
Outline
- International tax compliance
- Form 3520/3520-A
- Form 5471
- Penalties
- Managing audits and IRS examinations
- FBAR controversy
- Administrative appeals
- District court and U.S. Court of Federal Claims litigation
- Evolution of IRS "non-willful" standard
- 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
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
Mr. Cassidy is a Certified Public Accountant (New York) with more than 30 years of experience providing U.S. and international individual tax consulting and compliance services to international assignee executives, high net-worth individuals, investors as well as athletes & entertainers. He gained most of his experience working for some of the largest accounting public accounting firms, such as PwC, and recently with BDO as the U.S. National Tax Technical Leader for expatriate tax services. He spent several years living in Mexico City and Toronto, assisting clients with local and U.S. tax advice.
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Justin Donatello
Principal
KPMG
Mr. Donatello is a Managing Director in the KPMG Washington National Tax (“WNT”) Tax Controversy and... | Read More
Mr. Donatello is a Managing Director in the KPMG Washington National Tax (“WNT”) Tax Controversy and Dispute Resolution Services practice, which represents firm clients at all levels of controversy before the IRS. The practice represents clients at the examination and appeals level, using both traditional resolution methods and various alternative dispute resolution techniques such as mediation.
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
Mr. Patel’s practice concentrates on tax, international tax planning, estate planning, and elder law. His focus is on all tax matters including international tax law, foreign bank account disclosures, tax audit defense, and tax appeals. He has advocated over one hundred voluntary tax disclosures for assets before the US Internal Revenue Service. He is a frequent speaker and writer on legal issues affecting tax, foreign account planning, and estate planning.
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