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.
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.
Gain a working knowledge of all the foreign information returns. Identify key defenses to IRS criminal and civil penalties for erroneous foreign returns or non-filed foreign returns. Recognize the significance of the IRS voluntary disclosure policy as it relates to offshore transactions and accounts.
Arthur J. (Kip) Dellinger, Jr., CPA, senior tax partner at Kallman and Co. LLP, CPAs, is chair of the AICPA Tax Division Tax Practice Responsibilities Committee. He is the author of The Practical Guide to Federal Tax Practice Standards (CCH). His client practice focuses on sophisticated accounting issues and tax planning, compliance and controversy representation.
Mr. Dellinger has spoken before the USC Institute on Federal Taxation, the UCLA Tax Controversy Institute, the California Tax Bar Annual Meeting, several California CPA Education Foundation conferences, the Illinois CPA Society Annual Tax Conference and the Florida Institute of CPAs Tax Expo. He has written more than four-dozen articles on tax technical and procedural topics.
Non-Member Price $109.00
Member Price $79.00