News and Updates

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.

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.

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.

PFIC Training Series – PFIC Masterclass: Section 1291

This webinar will instruct in both the details and computations required to complete Form 8621 under the default §1291 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 §1291 theory as well as application on Form 8621.

Learning Objectives:

  • Describe the overall §1291 mechanism and its purpose.
  • Compute both excess and non-excess distribution amounts under §1291.
  • Complete a basic Form 8621 using the §1291 regime.
  • Transfer the tax items from a completed Form 8621 using the §1291 regime to the tax return.

Webinar Cost: $149.00 USD

Register for this course.

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

Practitioner’s Guide to the Sec. 965 Repatriation Tax

The Tax Cuts & Jobs Act completely redefined the U.S. tax regime for foreign corporations owned by U.S. persons. To facilitate this change, Congress imposed a one-time tax on certain offshore earnings: the learning curve is steep, the IRS issued guidance only last week, and the timeline for our clients is very short. This course outlines the who, what, when, where, and, most importantly, how of computing and paying this tax.

The learning objectives for this webinar include:

  • Recognize the new terminology and expanded definitions in §965.
  • Identify taxpayers who are subject to the §965 repatriation tax.
  • Apply IRS guidance to compute the §965 repatriation tax.
  • Prepare the election to pay the §965 tax over 8 years.

Watch the recorded webinar

Form 8621 Calculator – Walk-through training

(recorded: February 14, 2018)

In this hour long training video for the Form 8621 Calculator you will be presented with a detailed explanation of the work-flow, setting up clients and investment portfolios, a how to guide to complete form 8621s using our software. You will also learn how to make elections under Mark to Market, QEF, and OVDP. As well as tips and best practices to save you time and money when working with PFICs.

   View Training Video

IRS Sets Withholding Tables as GOP Pledges Paycheck Increase

By Alexis Leondis
Bloomberg

The Internal Revenue Service released guidance for employers about how much tax they should withhold from workers’ paychecks in 2018 — and said it would soon offer an online calculator employees can use to make sure the amounts are correct.

Companies have been awaiting details from the IRS, following the sweeping tax overhaul passed at the end of last month that changes tax rates and brackets, increases the standard deduction and repeals personal exemptions. Employers should begin using the new withholding tables as soon as possible, but not later than Feb. 15, according to the IRS notice issued Thursday.

Republicans have promised that American wage earners will see bumps in their paychecks starting in February — after employers have made the withholding adjustments. House Majority Leader Kevin McCarthy of California has said taxpayers should “check their check.”

Read the full article at bloomberg.com.

How Green Card holders can get the most out of TFSAs and RRSPs

By Cleo Hamel
MoneySense

Q.  I am a  Green Card holder as well as a Canadian resident, and have two questions: No.1. Which are the best securities to invest inside my TFSA to be “friendly” from an Internal Revenue Service and Federal Treasury Board (IRS/FTB) tax point of view? And No. 2. Which are the best securities to invest in an RRSP—again, to be “friendly” from an IRS/FTB tax point of view? Thank you, Mirjana G.

Hi Mirjana. Regarding your RRSP account, you can own any investment you like inside of an RRSP without any issue while you live in Canada. You may even want to hold any dividend-paying U.S .stocks inside your RRSP instead of a non-registered account.

Generally, dividends paid by U.S. companies to Canadians are subject to a tax treaty withholding rate of 15%. The tax treaty waives the withholding on U.S. stocks owned inside of RRSP accounts and is not subject to the passive foreign investment rules (PFICs)…

Read the full article at moneysense.ca.

Victims Of IRS’s Tea Party Bias — And Taxpayers — Must See Lois Lerner’s Testimony, Lawyer Says

By Legal Newsline
FORBES

Lois Lerner, formerly of the Internal Revenue Service when it discriminated against applicants for tax exemptions based on their viewpoints, claims Americans have no right to read statements she made under oath about why she did it.

Lerner, the former director of the IRS’s Exempt Organizations Division, wants U. S. District Judge Michael Barrett to maintain under seal a deposition she gave in June for a civil suit that victims brought in 2013. Unsealing it would place her safety in jeopardy, she says.

Her former IRS colleague, Holly Paz, seeks the same after they targeted groups with “tea party” names and groups that didn’t like how the government was run…

Read the full article at Forbes.com.