A 90-minute webinar for tax professionals, covering a range of some of the most complex topics U.S. expats currently face – including the way the IRS audits Americans abroad, the so-called Section 965 Transition Tax, the "exit tax" paid by wealthy Americans who are seeking to renounce, and other related subjects – will take place this Thursday, beginning at 1pm Eastern Daylight Savings Time (6pm British Summer Time, 7pm Central European Summer Time).
The webinar is being sponsored by Strafford Publications, an Atlanta-based provider of educational webinars and events for the legal and accounting professions, and will offer some viewers potential CLE (continuing legal education) and CPE (continuing professional education for CPAs and other accountants) accreditation, according to a detailed outline of the event on Stafford's website.
One of the three speakers will be Steven Toscher, managing principal of Hochman Salkin Toscher Perez P.C., a well-known tax controversy law firm based in Beverly Hills, who noted that the webinar comes at a time when published data shows that the IRS is "continuing to audit a higher proportion of expat tax returns," or around one in ten, than it does the returns of Homeland U.S. taxpayers.
"Considering the complexity of these expats' returns, it's not surprising," Toscher adds.
It also comes as the U.S. Congress is about to pass legislation known as the Inflation Reduction Act that is expected to provide an extra US$79 billion to the IRS over the next decade, which many commentators are predicting will increase its ability to scrutinize U.S. taxpayers' returns, particularly those of high-net-worth individuals, as a recent article in the Wall Street Journal noted.
Also scheduled to speak during Thursday's webinar are Michel R. Stein, also a principal of Hochman Salkin Toscher Perez, and Thomas M. Giordano-Lascari, a partner of Karlin & Peebles, a Los Angeles-based law firm.
Hochman Salkin Toscher Perez is well known for, among other things, having been where IRS Commissioner Charles Rettig worked for more than 30 years, prior to taking the top role at the IRS in 2018.
Some reasons expat tax
reporting is so complicated...
In its outline of the webinar's subject matter, Strafford points out that the tax filing rules for non-U.S.-resident American taxpayers "are often the reverse of those for residents," which it suggests is a starting point for confusion.
"The filing status Married Filing Jointly can require a special election," it continues. "Self-employed taxpayers usually are not entitled to deduct expenses. A simple presence in the U.S. for 183 days can trigger capital gains.
"Remarkably, two-thirds of expats [still] file these complicated returns on paper.
"In January 2020, the IRS began its compliance campaign focusing on Section 965 transition tax payments. The Service required these payments by U.S. shareholders of certain foreign corporations on unrepatriated (untaxed) earnings, as part of the 2017 Tax Act. The IRS stated that these audits could be expanded to other issues, particularly those relative to the 2017 Tax Act.
"Tax professionals and advisers working with individuals who have relocated abroad must understand the issues triggering these IRS audits, prepare clients for these audits, and know how to handle these demanding examinations."
Other topics scheduled to be addressed, the outline continues, include how best to handle un-filed returns, including FBAR filings; when a taxpayer should, and should not, consider filing an appeal; and how expats and tax advisers can best prepare for IRS examinations.
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- IRS Commissioner Rettig: 'We’re going after tax-evaders, not honest Americans'
- IRS announces surprise gift of penalty relief for late filers of tax year 2019, 2020 returns
- Expats worry about IRS crackdown, as Congress sends Inflation Reduction Act to Biden for enactment
- IRS reminder to Americans abroad: 'File your 2021 return by June 15; eligible families can claim expanded tax benefits'