The IRS has tripled its number of international examiners and has aggressively audited international tax issues, making it more important that taxpayers with an international tax issue to be prepared to defend their position on audit. Mr. Misey draws upon his experience at the IRS Chief Counsel (International) and his time working with multi-industry clientele to help attendees navigate today's international tax controversy landscape and be able to respond to and resolve IRS international tax audits. Formerly titled : International Tax Controversies With The IRS: Procedural and Substantive Issues
Learning Objectives
- Identify international tax issues the IRS is scrutinizing.
- Determine and explain the U.S. international tax audit process.
- Recognize opportunities for audit resolution.
Major Topics
- IRS tools to obtain information in an international audit, including information from foreign countries
- Dealing with IRS requests for foreign site visits
- Procedural tools for taxpayers to eliminate double taxation, such as the competent authority process
- Tips and traps of dealing with the IRS on audit issues, such as foreign tax credits, transfer pricing, and Subpart F
