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  • International Tax Update (2024)

Description


International Tax Update (2024) 


Navigating the complex landscape of information reporting for U.S. taxpayers with multinational activities can be daunting. Questions frequently arise about which forms are necessary for specific transactions or holdings.

This course will provide critical and applicable updates in the international tax arena. This presentation will cover case law rulings on foreign income inclusions, foreign tax credit treaty relief, and penalty imposition/assessment for multinational failures among other international tax topics of interest.

This program, taught by attorney Patrick J. McCormick, provides a summary of recent developments in international tax. Attendees will explore updated regulations for foreign tax credit purposes, as well as current options for net investment income tax relief under tax treaty provisions. Mr. McCormick will review recent rulings impacting the government's ability to assess and collect both FBAR and Title 26 penalties. He will also cover the domestic filing exception to Schedule K-2 and K-3 filing.


Learning Objectives:-

  • Overview of the latest changes and updates in international tax regulations
  • Analysis of recent rulings impacting the government's ability to assess and collect FBAR and Title 26 penalties
  • Current options for relief under various tax treaty provisions
  • Examination of the domestic filing exception to Schedule K-2 and K-3 requirements
  • Recognize service issuances impacting multinational tax issues
  • Identify how actions from the United States Congress affect international tax
  • Detailed exploration of updated regulations for foreign tax credit purposes
  • Identify the primary information reporting forms that are relevant for U.S. taxpayers involved in multinational activities
  • Describe the specific circumstances that trigger various reporting requirements for international tax contexts
  • Evaluate the types of transactions and holdings that necessitate different forms, ensuring compliance with U.S. tax laws

 

 Session Highlights:-

  • Summarize the recent developments in international tax 
  • Explore the recent rulings impacting the government's ability to assess and collect both FBAR and Title 26 penalties
  • Identify the current status of NIIT relief under treaties
  • Review the domestic filing exception to Schedule K-2 and K-3 filing


Who Will Benefit:

  • CPA
  • Enrolled Agents (EAs)|
  • Tax Professionals
  • Attorneys
  • Other Tax Preparers
  • Finance professionals
  • Financial planners
  • Business Owners


Credits and Other information:-

      - Session Duration: 2 Hours

      - Case Studies and Live Q&A session with speaker

      - Power Point presentation for reference

      - Session learning level: Introductory

      - Delivery method: Group Internet Based

      - IRS Credits: 2 Tax Hours

       - Recommended field of study – Taxes

       - Session Prerequisites and preparation: None

       - Location: Virtual/Online

       - Attendance Requirement:  Yes


Speaker Profile:

Patrick McCormick, JD, LLM

Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including Pioneer Educator, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.


International Tax Update (2024)

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