The year's update reviews the life-cycle of an international tax
controversy including (a) the most common errors on returns required
to be filed by US Persons reporting foreign assets and income, (b) the
procedures used by the IRS to determine a liability based on foreign
income, deductions, and assets, (c) the options available to contest
and compromise the international adjustments and penalties before the
IRS Office of Appeals, including accelerated appeals, collection due
process hearings, and (d) the best practices for litigating
international issues in the Tax Court and other federal courts.
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22/06/2018 Last update