This seminar will cover recent changes in international tax compliance, as FATCA and the Offshore Voluntary Disclosure Programs put international business and investment under the microscope. It will cover the “do’s and don’ts” of international business operations and combinations in this Brave New World.
The IRS is attempting to adapt to the increasing globalization of businesses and economic activity. In doing so, the Internal Revenue Service is refocusing its examination procedures, moving from specific return-based examinations towards a bigger picture analysis. The LB&I Division of the IRS has created a new “Global High Net Worth” component, whose mission is to look at the tax returns of all entities associated with high wealth/high income taxpayers.
Moreover, in light of increased information sharing among both OECD and non-OECD countries, practitioners need to understand how the new information sharing agreements will affect their clients. Business owners who operate overseas need to understand the complexities and potential pitfalls of the information sharing agreements.
The information gained in this seminar will help attorneys guide their business and individual clients, and avoid costly mistakes when it comes to the taxing authorities’ review of their clients’ cross-border businesses and investments.
Downloadable products must be downloaded before it expires on November 16, 2013.
Who Should Attend:
Attorneys & Legal Staff
Friday, Nov. 16, 2012
| 9:00||Introduction and Overview|
Chicoine & Hallett PS
Group Mgr., Tax Controversy,
| 9:15||Foreign Account Tax Compliance Act
What You Need to Know About the Foreign
Account Tax Compliance Act (FATCA):
New Burdensome Forms and 400 Pages of
Garvey Schubert Barer
|10:30||Implications of Offshore Investments|
Taxation; Reporting; Updates on FBAR
Reporting and Voluntary Disclosures
LeSourd & Patten PS
LeSourd & Patten PS
Corporate & Tax Information; Organization
for European Economic Cooperation
and Development (OECD); Information
Sharing: Are There Any Tax Havens Left?
Chicoine & Hallett PS
| 1:15||The New Global High Net Worth
IRS Examinations Focus on “Big Picture”
Net Worth and All Related Returns/
Entities; The Australian Experience
Chicoine & Hallett PS
| 2:15||M&A and Business Combinations|
Cross Border Acquisitions; What You
Need to Know About Foreign Partners and
Lane Powell PC
| 3:30||New Economy and Doing Business
Will the IRS Reach out and Touch Your
“Effectively Connected Income” (ECI)?
Reducing Your Tax Liability the “Google”
Jenny Coates Law PLLC
John Colvin, Program Co-Chair, an attorney with Chicoine & Hallett PS, concentrates his practice in federal tax controversy matters and federal white-collar criminal defense. He also has significant experience in white-collar cases involving fraudulent medical billings, customs violations, securities and commodities fraud, software piracy, bank and bankruptcy fraud, environmental crimes, and Lacey Act violations.
Cori E. Flanders-Palmer, Program Co-Chair, an attorney with Microsoft Corporation, is the firm's Group Manager of Tax Controversy. She has worked with compliance issues, defended legal positions inside and outside of the courtroom, and written legal opinions supporting various tax positions.
Robert J. Chicoine, a founder of Chicoine & Hallett PS, has been in private practice since 1977. Criminal tax and white-collar criminal defense, and civil tax litigation, are a major focus of his practice, as well as business, real estate, federal and state tax, estate planning, tax aspects of divorce, and tax litigation. From 1971-77, he was a Tax Attorney with the Office of Chief Counsel, Internal Revenue Service.
Jenny Coates is the founder of Jenny Coates Law PLLC, a boutique tax and business law practice. With 20 years of experience at prominent international law firms, she provides practical, creative solutions to diverse tax issues. After moving to the Northwest in 2006, she focused on complex transactions as a member of the cross-border Canadian tax practice group of a large international law firm.
Paige L. Davis, a shareholder with Lane Powell PC, concentrates her practice on cross-border tax and business planning for U.S. and foreign entities. She counsels clients on all aspects of transactions, including formation, operation, exit strategies, mergers and acquisitions, financing and other business operations. Her practice also includes tax aspects of aircraft ownership, transactions and financing.
Darek M. Jarski is a principal with LeSourd & Patten PS. His practice consists of tax controversy matters before the Internal Revenue Service, including helping clients resolve off-shore compliance issues, complex IRS audits, voluntary disclosures, representing non-filers, tax collection matters, penalty abatements, information return compliance issues and criminal tax defense.
Robert M. McCallum, a principal with LeSourd & Patten PS, emphasizes the resolution of civil and criminal tax matters before the Internal Revenue Service and the Washington State Department of Revenue. He was previously a federal prosecutor with the Criminal Tax Section of the U.S. Department of Justice and an Attorney-Advisor with the U.S. Tax Court in Washington, DC.
Gary P. Tober, an owner with Garvey Schubert Barer, has been practicing law for over 35 years. He advises U.S. and foreign corporations, partnerships and individuals in tax and business planning matters. He also consults and renders U.S. tax opinions to foreign governments and foreign pension funds investing in U.S. corporations, start-up enterprises and real estate located in the U.S.
This seminar is approved for the following credits
This course has been approved by the Washington State Bar for 5.75 hours of Washington MCLE credit.
This seminar has been approved by the National Federation of Paralegal Associations for 6.0 hours of Continuing Legal Education credits.
This course may qualify for CPE credits; please check with your state board's requirements.
If this seminar has not been approved for the credits you require, let us know and we will look into it for you.
Information on Continuing Education Credits
|2 or more (each)
|Non-Profit / NGO
|Printed Course Materials
|Downloadable Course Materials
We will refund your tuition less a $50 cancellation charge if we receive your cancellation by 11/9/2012.
|This seminar is being held at:
|Crowne Plaza Seattle
1113 Sixth Avenue
Seattle, WA 98101
Please call the venue for directions/questions.
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