Best practices for managing international tax controversies

Event overview

The IRS is renewing its focus on international issues. What does this mean for your current (or future) IRS examination? Join us to learn how to best position yourself to resolve your international tax controversies.

Discussion topics:

• Strategies to resolve foreign tax credit issues with the IRS
• Obtaining waivers or abatements of international information return penalties
• New IRS pre-payment appeals process for assessed penalties
• Transfer pricing documentation and the mandatory Information Document Request (IDR)

Learning objectives

Participants will:

• Learn about the IRS’s renewed focus on international transactions and reporting issues.
• Gain insights into the resolution of foreign tax credit controversies that are impacted by the Bank of New York Mellon v. Comm’r.
• Be introduced to alternative ways to avoid, eliminate or reduce international information reporting penalties.
• Be better prepared to respond to the mandatory IDR on transfer pricing documentation.

Panelists include:

Patti Burquest, principal, Washington National Tax
Ramon Camacho, principal, Washington National Tax
David Click, director, Denver, Colorado