CPE: 2 hours
Advanced prep: None
Who should attend: CPAs and financial professionals in public practice advising clients and businesses.
The IRS has tripled the number of its international examiners and has aggressively audited international tax issues. Taxpayers with an international tax issue must be prepared to defend their position on audit. Our instructor will draw upon his experience at the IRS Chief Counsel (International) and his work with clients in a variety of industries to help you navigate today's difficult international tax controversy landscape and successfully respond to and resolve IRS international tax audits.
- Identify international tax issues the IRS is scrutinizing.
- Determine and explain the U.S. international tax audit process.
- Recognize opportunities for audit resolution.
- International tax audit issues
- IRS tools to obtain information in an international audit, including information from foreign countries.
- Dealing with IRS requests for foreign site visits.
- Taxpayer procedural tools to eliminate double taxation, such as the competent authority process.
- Tips and traps of dealing with the IRS on audit issues, such as foreign tax credits, transfer pricing and Subpart F.