To excel as a tax practitioner in an increasingly global marketplace, you must familiarize yourself with the preparation of tax forms for clients conducting foreign transactions or with assets in international accounts.
Gain a thorough understanding of foreign information return reporting requirements and useful techniques to determine whether or not your clients may encounter foreign income tax problems.
Attain a working knowledge of IRS and Department of Treasury foreign information returns to effectively represent clients and comply with Circular 230. All concepts will be discussed in light of the resurrected IRS foreign voluntary disclosure program, which reduces the foreign information return burden.
Gain a working knowledge of all the foreign information returns.
Identify key defenses to IRS criminal and civil penalties for erroneous foreign returns or nonfiled foreign returns.
Regognize the significance of the IRS voluntary disclosure policy as it relates to offshore transactions and accounts.
Level of Difficulty:
IRS foreign information returns and Civil Penalties Information Chart
Report of Foreign Bank and Financial Accounts: Form TD F 90-22.1 (FBAR)
FBAR penalty mitigation rules
Statement of Specified Foreign Financial Assets: Form 8938
Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Gifts: Form 3520
Annual Information Return of Foreign Trust with a U.S. Owner: Form 3520-A
Information Return of U.S. Persons with Respect to Certain Foreign Corporations: Form 5471
Information Return of a 25% Foreign-Owned or a Foreign Corporation Engaging in a U.S. Trade or Business: Form 5472
Return by a U.S. Transfer of Property to a Foreign Corporation: Form 926
Return of U.S. Persons with Respect to Certain Foreign Partnerships: Form 8865
Information Return of U.S. Persons with Respect to Foreign Disregarded Entities: Form 8858
Return by Shareholder of a Passive Investment Company or Qualified Electing Fund: Form 8621
Current procedures for participation in the IRS Offshore Voluntary Disclosure Program (OVDP), including the IRS general voluntary disclosure policy, OVDP election into the program, statements, worksheets, penalties, PFIC alternative computation, FAQs and more
Assumes some knowledge of all types of tax returns.
Tax practitioners who want to enhance their understanding of the foreign procedural tax regime.
This course will adjourn at 4 p.m.