Understanding International Tax Enforcement Issues in 2010-2011

Summary:

Each year, international tax law and its enforcement become ever more complicated and with a torrent of new financial regulations, 2010-2011 is shaping up to be very active in this area. International tax professionals need to be in the know with respect to the changes in order to avoid costly consequences. The Knowledge Group has assembled a panel of key experts and thought leaders to give you an overview of International Tax Enforcement. Some of the topics to be covered in this 2-hour LIVE webcast are: · Taxation of resident and non-resident aliens · Special rules for temporary aliens · Tax withholding of foreign persons · Tax treaties · Forms and due dates · Miscellaneous international tax issues · Developments in international taxation

Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Group, LLC
Recommended CLE/CPE Hours: 2.0
Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.
Advance Preparation: Print and review course materials
Course Code: 104026

SEGMENT 1:
John L. Harrington, Partner (Former International Tax Counsel, Department of Treasury),
SNR Denton US LLP

Businesses are facing greater compliance burdens
    - Proposal for reporting uncertain tax positions
    - New withholding and reporting rules enacted in March
    - New international tax provisions enacted in August
Increased international cooperation between tax authorities
    - Greater sharing of tax information through tax treaties and tax information exchange agreements
    - Coordinated activities by tax authorities (JITSIC, OECD, etc.)
Operating under increased domestic and international scrutiny


SEGMENT 2:
Nathan J. Hochman, Partner (Former Assistant Attorney General, Tax Division, U.S. Department of Justice),
Bingham McCutchen LLP

- Focus of IRS and Department of Justice on criminal tax prosecutions of those violating FBAR rules. I can discuss the recent Voluntary Disclosure Program, its advantages and disadvantages, and where beyond Switzerland the enforcement effort will go.
- Focus of IRS and Department of Justice on criminal tax prosecutions of those using international entities and offshore banks and financial institutions to engage in tax evasion.

SEGMENT 3:
James Wall, JD, LLM, Principal, Director, International Tax Services Group),
J.H. Cohn LLP

Focus on withholding taxes as a tier one issue
Increased enforcement efforts by tax authorities around the world in relation to transfer pricing
    - How do businesses deal with differing documentation requirements
    - What should taxpayers be doing before and after an audit
Increased focus on information reporting for non-US entities (5471, 8858, 8865, etc.) and penalty exposure
FBAR reporting

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Who Should Attend?

- Tax Counsel
- General Counsel
- Accountants
- CPAs
- International Tax Lawyers/Consultants
- Senior Management
- Finance Executives

Why Attend?

This is a must attend event for all tax professionals to hear the latest and up to the minute issues and facts surrounding the international tax enforcement for the year 2010-2011.
- Detailed guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A

Understanding International Tax Enforcement Issues in 2010-2011
LIVE Webcast

Wednesday, November 3, 2010

3:00pm to 5:00pm (ET)