International Penalties and Abatement Strategies

Date:  December 4, 2018
Time: 2pm – 4pm EDT
Instructor:  Mary Beth Lougen, EA, USTCP
IRS Program Number:  NMVBP-T-00114-18-O

The IRS is focusing their resources on international tax compliance; as such, practitioners are seeing increasing numbers of examinations in this area along with FBAR and international information return penalties. We will discuss in detail methods to defeat these penalties, such as reasonable cause, as well as how to effectively represent clients in either an international non-compliance examination or penalty abatement engagement. In addition, we will look at case studies to bring a real-life perspective to these issues.

Learning Objectives:

• Describe the penalty structures for FBARs and other international information returns.
• Explain “reasonable cause” in the context of FBAR and international information return penalties and how to effectively demonstrate reasonable cause and advocate for your client.
• Understand the different ways to contest FBAR and international information return penalties both pre-assessment and post-assessment.

Webinar Cost:  $149.00

GILTI Fundamentals

Date:  November 27, 2018
Time: 2pm – 4pm EDT
Instructor:  Mary Beth Lougen, EA, USTCP
IRS Program Number:  NMVBP-T-00113-18-O

This course will demystify the new global intangible low tax income (GILTI) regime that takes effect for many taxpayers in 2018. We will provide an overview of the regulations and their intent, define the new terms of art in the regulations, calculate GILTI, demonstrate how the regulations affect entities and individuals differently, and what strategies are available to mitigate potential tax consequences.

Learning Objectives:

• Identify what taxpayers are subject to GILTI taxation.
• Compare and contrast the taxation of entities and individuals under the GILTI regime.
• Understand the calculations of tested income.
• Describe potential strategies to mitigate GILTI taxation.

Webinar Cost:  $149.00

PFIC Masterclass: QEF & MTM

Date:  October 30, 2018
Time: 2pm – 4pm EDT
Instructor:  Mary Beth Lougen, EA, USTCP
IRS Program Number:  NMVBP-T-00112-18-O

This webinar will instruct in both the details and computations required to complete Form 8621 under the qualified electing fund (QEF) and mark-to-market (MTM) regulations. This is a course aimed at practitioners that have an intermediate level of understanding of PFIC taxation. The materials will be computation-intensive and will cover both QEF and MTM theory as well as application on Form 8621.

Learning Objectives:

• Describe the overall QEF and MTM mechanisms and their purposes.
• Analyze the benefits and drawbacks of the QEF and MTM elections.
• Complete a basic Form 8621 using the QEF and MTM regimes.
• Transfer the tax items from a completed Form 8621 using the QEF and MTM regimes to the tax return.

Webinar Cost:  $149.00

PFIC Masterclass: Section 1291

Date:  October 23, 2018
Time: 2pm – 4pm EDT
Instructor:  Mary Beth Lougen, EA, USTCP
IRS Program Number:  NMVBP-T-00111-18-O

This webinar will instruct in both the details and computations required to complete Form 8621 under the default §1291 regulations. This is a course aimed at practitioners that have an intermediate level of understanding of PFIC taxation. The materials will be computation-intensive and will cover both §1291 theory as well as application on Form 8621.

Learning Objectives:

• Describe the overall §1291 mechanism and its purpose.
• Compute both excess and non-excess distribution amounts under §1291.
• Complete a basic Form 8621 using the §1291 regime.
• Transfer the tax items from a completed Form 8621 using the §1291 regime to the tax return.

Webinar Cost:  $149.00

PFIC Taxation Fundamentals

Date:  October 16, 2018
Time: 2pm – 4pm EDT
Instructor:  Mary Beth Lougen, EA, USTCP
IRS Program Number:  NMVBP-T-00110-18-O

This course is the first in the Passive Foreign Investment Companies series training, that gives a broad overview of the tax law related to passive foreign investment companies, or PFICs.  Failing to properly file Form 8621 can expose your client to both onerous penalties and an unlimited statute of limitations for the assessment of tax.  Even though the PFIC provisions are among the most complicated and punitive sections of the Internal Revenue Code, we will explain PFICs in plain English so you can explain them to your clients.

Learning Objectives:

• Explain what qualifies as a PFIC and how to identify them.
• Describe when a taxpayer must file Form 8621.
• Compare and contrast the three different taxation regimes for PFICs.
• Understand the potential penalties & statute of limitation issues with PFIC non-compliance.

Webinar Cost:  $149.00

Series 1 – Fundamentals of International Tax

• 9/18: Introduction to International Tax – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00107-18-O)
• 10/2: Mechanisms for Offsetting U.S. Taxation of Foreign Income – Thomas Gorczynski, EA, USTCP (IRS Program Number NMVBP-T-00109-18-O)

Series 2 – Passive Foreign Investment Companies

• 10/16: PFIC Taxation Fundamentals – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00110-18-O)
• 10/23: PFIC Masterclass: Section 1291 – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00111-18-O)
• 10/30: PFIC Masterclass: QEF & MTM – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00112-18-O)

Series 3 – Advanced International Tax Issues

• 11/27: GILTI Fundamentals – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00113-18-O)
• 12/4: International Penalties and Abatement Strategies – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00114-18-O)
  12/11: Fixing International Non-Compliance – Thomas Gorczynski, EA, USTCP (IRS Program Number NMVBP-T-00115-18-O

Join special guest instructor Mary Beth Lougen, EA, USTCP for the Compass Tax Educators webinar “Practitioner’s Guide to the Sec. 965 Repatriation Tax” on April 3, 2018. Other members of the Compass Tax Educators team will also be available on this webinar to moderate the event and answer questions.

The Tax Cuts & Jobs Act completely redefined the U.S. tax regime for foreign corporations owned by U.S. persons. To facilitate this change, Congress imposed a one-time tax on certain offshore earnings: the learning curve is steep, the IRS issued guidance only last week, and the timeline for our clients is very short. This course outlines the who, what, when, where, and, most importantly, how of computing and paying this tax.

The learning objectives for this webinar include:

• Recognize the new terminology and expanded definitions in §965.
• Identify taxpayers who are subject to the §965 repatriation tax.
• Apply IRS guidance to compute the §965 repatriation tax.
• Prepare the election to pay the §965 tax over 8 years.