PFIC Training: Identification, reporting, elections

2017 International Tax Program in NYC 1717 Broadway, New York, NY, United States

A 2-hour primer on passive foreign investment companies- what are they, how are they taxed, what are the various elections […]

PFIC Training – Form 8621 Case Study

2017 International Tax Program in NYC 1717 Broadway, New York, NY, United States

A 2-hour session on preparing Form 8621. Hands on form completion scenarios including 1291 default taxation, mark to market, unreversed […]

PFIC Training Series – PFIC Taxation Fundamentals

This course is the first in the Passive Foreign Investment Companies series training, that gives a broad overview of the tax law related to passive foreign investment companies, or PFICs. Failing to properly file Form 8621 can expose your client to both onerous penalties and an unlimited statute of limitations for the assessment of tax. Even though the PFIC provisions are among the most complicated and punitive sections of the Internal Revenue Code, we will explain PFICs in plain English so you can explain them to your clients.

Learning Objectives:

  • Explain what qualifies as a PFIC and how to identify them.
  • Describe when a taxpayer must file Form 8621.
  • Compare and contrast the three different taxation regimes for PFICs.
  • Understand the potential penalties & statute of limitation issues with PFIC non-compliance.

Webinar Cost: $149.00 USD

Watch the recorded webinar

$149.00

PFIC Training Series – PFIC Masterclass: QEF & MTM

This webinar will instruct in both the details and computations required to complete Form 8621 under the qualified electing fund (QEF) and mark-to-market (MTM) regulations. This is a course aimed at practitioners that have an intermediate level of understanding of PFIC taxation. The materials will be computation-intensive and will cover both QEF and MTM theory as well as application on Form 8621.

Learning Objectives:

  • Describe the overall QEF and MTM mechanisms and their purposes.
  • Analyze the benefits and drawbacks of the QEF and MTM elections.
  • Complete a basic Form 8621 using the QEF and MTM regimes.
  • Transfer the tax items from a completed Form 8621 using the QEF and MTM regimes to the tax return.

Register for this course.

$149.00

Advanced International Tax Issues – GILTI Fundamentals

This course will demystify the new global intangible low tax income (GILTI) regime that takes effect for many taxpayers in 2018. We will provide an overview of the regulations and their intent, define the new terms of art in the regulations, calculate GILTI, demonstrate how the regulations affect entities and individuals differently, and what strategies are available to mitigate potential tax consequences.

Learning Objectives:

  • Identify what taxpayers are subject to GILTI taxation.
  • Compare and contrast the taxation of entities and individuals under the GILTI regime.
  • Understand the calculations of tested income.
  • Describe potential strategies to mitigate GILTI taxation.

Register for this course.

$149.00

Training: International Penalties and Abatement Strategies

Date: December 4, 2018
Time: 2pm - 4pm EDT

The IRS is focusing their resources on international tax compliance; as such, practitioners are seeing increasing numbers of examinations in this area along with FBAR and international information return penalties. We will discuss in detail methods to defeat these penalties, such as reasonable cause, as well as how to effectively represent clients in either an international non-compliance examination or penalty abatement engagement. In addition, we will look at case studies to bring a real-life perspective to these issues.

Learning Objectives:

  • Describe the penalty structures for FBARs and other international information returns.
  • Explain “reasonable cause” in the context of FBAR and international information return penalties and how to effectively demonstrate reasonable cause and advocate for your client.
  • Understand the different ways to contest FBAR and international information return penalties both pre-assessment and post-assessment.

Webinar Cost: $149.00 USD

Register for this course.

$149.00