Streamlined Filing Compliance Procedures: IRS Foreign and Domestic Amnesty Programs
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will guide international tax advisers through streamlined compliance programs offered by the IRS to bring taxpayers up to date on their tax and foreign reporting obligations. Our authoritative panel will explain eligibility requirements and required documentation as well as offer advice to facilitate acceptance and resolution of past noncompliance.
Outline
- Streamlined Foreign Offshore Procedures (SFOP)
- Streamlined Domestic Offshore Procedures (SDOP)
- Required submissions
- Income tax returns
- Information returns
- Certification statements
- Expatriation and Section 965 transition tax
- Handling an audit
- Avoiding common errors
- Alternatives to SFOP and SDOP
Benefits
The panel will cover these and other critical issues:
- What is considered nonwillful noncompliance under the streamlined compliance programs?
- How the five percent Title 26 penalty is calculated for the SDOP
- Which taxpayers are eligible for the SFOP?
- What common errors should practitioners avoid when filing for relief under the streamlined compliance programs?
Faculty
Alicea Castellanos, CPA, TEP, N.P.
CEO & Founder
Global Taxes
Ms. Castellanos is the CEO and Founder of Global Taxes LLC. She provides personalized U.S. tax advisory and compliance... | Read More
Ms. Castellanos is the CEO and Founder of Global Taxes LLC. She provides personalized U.S. tax advisory and compliance services to high net worth families and their advisors. Ms. Castellanos has more than 20 years of experience. Prior to forming Global Taxes, she founded and oversaw operations at a boutique tax firm, worked at a prestigious global law firm and CPA firm. Ms. Castellanos specializes in U.S. tax planning and compliance for non-U.S. families with global wealth and asset protection structures which include non-U.S. trusts, estates and foundations that have a U.S. connection. She also specializes in foreign investment in U.S. real estate property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures/tax amnesties, FATCA registration, and foreign companies wanting to do business in the U.S. Ms. Castellanos is fluent in Spanish and has a working knowledge of Portuguese. She is an active full member of the Society of Trusts & Estates Practitioners (STEP), the New York State Society of Certified Public Accountants (NYSSCPAs), the American Institute of Certified Public Accountants (AICPA), the International Fiscal Association (IFA), a member of Clarkson Hyde Global, a world-wide association of accountants, auditors, tax specialists and business advisors and the International Advisory Experts (IAE). Ms. Castellanos has chaired the annual NYSSCPA International Tax Conference for 3 years in a row. Distinctly, in 2020, she was awarded with a prestigious NYSSCPA Forty Under 40 Award. Ms. Castellanos was selected as someone that has notable skills and is visibly making a difference in the accounting profession. She has also been recognized as a leading expert for Tax advice and she has been invited to join Advisory Excellence, as their exclusively recommended tax expert in the USA.
In 2021, Ms. Castellanos was the Gold Winner of Citywealth's 2021 Powerwomen Awards in the category USA - Woman of the Year - Business Growth (Boutique).
In 2022, she was the Silver Winner of Citywealth's 2022 Powerwomen Awards in the category USA - Woman of the Year - Business Growth (Boutique).
Global Taxes and Ms. Castellanos received a nomination for the Magic Circle Awards 2022 edition. For Global Taxes as Accountancy Firm of the year - US and for Alicea Castellanos as the Accountant of the year category.
She was selected by Citywealth as one of the Top 10 Accountants of 2021 serving the Ultra High-Net-Worth Individual (UHNW) segment of the market. The members of the list were selected through thorough independent research undertaken by the editorial team who took into consideration both peer and client feedback.
Furthermore, Ms. Castellanos is currently listed in the Global Elite Directory 2022-23, which is an annual exclusive directory of the world's elite lawyers and outstanding wealth advisors advising ultra-high net-worth clients.
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Melvin A. Warshaw, JD, LLM
International Tax and Estate Planning Lawyer
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Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S.... | Read More
Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S. and non-U. S. high net worth individuals, families and companies on a wide range of personal and business tax matters, especially in connection with cross-border income and estate tax planning and compliance in the U. S. Mr. Warshaw is admitted to practice in the Commonwealth of Massachusetts. He regularly advises non-U. S. clients on structuring inbound pre-immigration tax strategies including basis step-up in legacy assets, avoiding the U. S. CFC and PFIC anti-deferral tax regimes, optimizing use of foreign tax credits, minimizing green card status as well as advising on and drafting of “drop-off trusts.” Mr. Warshaw also advises long-term green card holders and U. S. citizens on planning to minimize their U. S. exit tax through gift programs, managing equity compensation and by drafting “expatriation” trusts and considerations of a change of domicile outside the U. S. He has also counseled clients in complying with their U. S. tax filing obligations by engaging accountants and bringing such taxpayers into compliance with their numerous U. S. international tax reporting requirements. Mr. Warshaw has also advised on the U. S. international tax aspects of cryptocurrency, including how to become U. S. tax compliant and how to mitigate U. S. tax implications prior to and following renouncing U. S. citizenship.
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