This course will focus on international information reports (e.g., Form 3520, 5471, 8938, etc.) and the situations triggering their filing requirements. We will also discuss the penalties for failing to comply with these filing requirements. Then, we will discuss what happens when you discover that a taxpayer has been non-compliant (i.e., what are their options?). We will examine the different options available to non-compliant taxpayers. Finally, we will discuss what happens after taxpayers have been penalized (i.e., how to litigate these foreign penalties).
Learning Objectives:
Withers Bergman LLP
Senior Associate
[email protected]
Phil is a senior associate at Withers Bergmen LLP (Withers Worldwide). Phil’s practice is focused on domestic and international tax controversy. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts. He has represented clients from audit through trial and, if necessary, at the appellate level.
Phil has spoken on various tax topics and at various forums, including the American Bar Association, New York County Lawyers' Association, IRS Nationwide Virtual Tax Forum, CPA Academy, and NYU Tax Controversy Forum. He has also published several tax-related articles, which have been published by Tax Notes, Bloomberg BNA, Journal of Tax Practice and Procedure, EA Journal, and The Practical Lawyer. In addition to his publication and speaking engagement, he is heavily involved with the American Bar Association, where he is the incoming Chair of the Tax Collections Bankruptcy and Workouts Committee.
Withers Bergman LLP
Senior Associate
[email protected]
(203) 974-0387
Michael's practice focuses on domestic and international tax planning, compliance, and controversy resolution for individuals and closely held businesses. His experience includes examinations, collection matters, appeals hearings (including collection due process hearings), advising clients on international and domestic filing requirements, advising clients on compliance options, and US international inbound and outbound tax planning for individual and entity taxpayers.
Michael has spoken on various tax topics and at various forums, including the International Fiscal Association and most recently on Current Issues Shaping Tax Controversy before the Knowledge Group. He has also published several tax-related articles and has been quoted by various publications including USA Today.
Withers Bergman LLP
Associate
[email protected]
(617) 613-9707
Thomas focuses his practice on domestic and international tax planning, compliance, and controversy resolution for individuals and closely held businesses. Thomas is experienced in the areas of domestic and international taxation, international tax planning and compliance for businesses and individuals, contracts, and corporate law. He specializes in advising clients on the U.S. tax consequences of cross-border transactions, domestic and international withholding tax, FATCA and CRS reporting, legal and tax aspects of operating a business outside the U.S., structuring corporate transactions, tax treaty analysis, and compliance issues relating to U.S. tax and information reporting. Prior to joining Withers, Thomas worked at an accounting firm as part of the international tax group.