This course covers the streamlined procedures in exquisite detail since the IRS expanded the procedures back on June 18, 2014.
Please Note: This course is eligible for IRS credit. If you need credit reported to the IRS for this program, please download the IRS CE request form on the Materials Tab after you purchase the program and submit to firstname.lastname@example.org.
*Understand the major changes to the procedures since the IRS expanded them back on June 18, 2014
*An overview of the two types: streamlined foreign procedures and streamlined domestic procedures
*Understand the requirements for each and the subtleties that are so easy to overlook that they are a veritable trap for the unwary
*Understand the differences between each
*Understand the penalty structure under streamlined domestic -- commonly referred to as the miscellaneous offshore penalty -- including the types of assets that are included in the penalty base, how it captures a wider array of foreign assets than the miscellaneous penalty under OVDP, and how the penalty itself is calculated
*Answers to the most frequently asked questions regarding the streamlined procedures
*What does it mean for a taxpayer to certify that he/she was non-wilful in his failure to report his foreign assets for purposes of streamlined
*The elusiveness of non-willfulness
*Can your client successfully certify that his failure to disclose his foreign assets was truly non-willful? What are some things that are sure to attract the IRS's attention
*Don't try and fit a square peg into a round hole! Consequences of IRS rejecting a streamlined submission when your client is not an appropriate conduct and the parade of horribles that could follow
*IRS guidance for when it's appropriate to make a "quiet disclosure."
*Practical and sound advice regarding whether to go streamlined or go home
|Important CPE Credit Information_2015 (0.02 MB)||Available after Purchase|
|Streamlined Webinar Presentation (2.41 MB)||37 Pages||Available after Purchase|
|IRS CE Credit Request form (0.14 MB)||Available after Purchase|
Michael is a trial lawyer who specializes in U.S. international taxation. He assists U.S. citizens and residents navigate the labyrinth of foreign asset reporting requirements. Michael is known for his creativity, his charismatic personality, and his unyielding dedication to his clients.
As a former public defender, Michael has defended the poor, the forgotten, and the damned against a government that has seemingly unlimited resources to investigate and prosecute criminal allegations.
Michael is a prolific writer and a passionate blogger. He has written articles that have been featured in leading tax journals such as CCH Journal of Tax Practice and Procedure, Global Tax Weekly, and ABA News Quarterly. He has also been featured on the media affiliates of several major media networks, including NBC, ABC, CBS, Fox, and CNN.
Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey’s rising stars of the legal profession.
FBAR webinar (at very least); OVDP webinar (recommended)
Tax professionals (lawyers, CPAs, EAs) and end-users (i.e., taxpayers)
Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417. Web site: www.nasba.org
Group Internet Based
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