Congress and the IRS have recently imposed numerous filing requirements on individuals and businesses with international business and investment activities. The absence of these information forms from taxpayers’ tax returns has been the focus of recent offshore audits and has resulted in hefty penalties.
This webinar, offered by two leading tax controversy attorneys, will discuss the filing requirements and penalties that may apply in the context of: (1) investments in foreign bank and financial accounts; (2) treaty-based tax reporting positions; (3) foreign tax credits; (4) nonresident aliens who have filing obligations in the United States; (5) nonresident aliens who spend time in the United States; and (5) taxpayers who have investments in corporations, partnerships, and disregarded entities.
This webinar will also discuss strategies by which practitioners can proactively eliminate their clients’ exposure to such penalties before an audit and best practices to defend against such penalties in connection with an ongoing audit or investigation.
This webinar is a must-attend for practitioners who have clients with international business and investment activities.
McCarter & English, LLP
Attorney
[email protected]
9736392081
Lawrence (“Larry”) Sannicandro is an associate in the Tax, Employee Benefits & Private Clients Practice Group who concentrates his practice on tax controversy and tax planning matters. He represents businesses, estates, trusts, and individuals at all stages of tax controversies, including in audits, before the IRS Office of Appeals, and in litigation before the United States Tax Court, the U.S. Court of Federal Claims, the U.S. District Courts, and the U.S. Courts of Appeals.