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International Information Reporting Basics, Noncompliance, and Litigation

INTERNATIONAL INFORMATION REPORTING BASICS, NONCOMPLIANCE, AND LITIGATION

Cost Free
Presentation Length 2.0 hours

Recorded DateJuly 5, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

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:


  • Identify the basic requirements for international information returns

  • Recognize the specific situations that necessitate the filing of international information returns

  • Determine the penalties for failing to file timely or accurate international information returns

  • List the available options to advise non-compliant taxpayers

  • Recall the fundamentals of international penalty litigation

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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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.

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Michael Steffany

Withers Bergman LLP
Senior Associate 
[email protected]
(203) 974-0387

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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.

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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.

About Our Presenter

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For the past 125 years Withers Bergman has been proud to assist some of the world's most remarkable individuals and organisations in realising their ambitions and using private capital to transform the world around them. They are the largest law firm in the world dedicated to the needs of successful people, their families, their businesses and their philanthropic activities. With offices across the United States and the Caribbean, Europe and Asia-Pacific, they provide coverage that other law firms with their focus cannot.