An in-depth look at the dozens of complex requirements for the filing of IRS Form 926 by U.
S. persons, estates and trusts who engage in exchanges or transfers of property to a foreign corporation. The IRS is vigilant about preventing taxpayers from hiding offshore assets and earnings. Furthermore, in recent years the IRS has become increasingly aggressive about enforcing cross-border corporate reorganizations, divisions, and liquidations. Failure to file, misfiling, or underreporting can have substantial consequences with no statute of limitations. This course includes practical applications you can apply to client situations and will add to your overall knowledge about international tax compliance as it applies to U.S. investors and businesses with overseas holdings, as well as U.S. owners and beneficiaries of foreign trusts. You will learn, step-by-step, how to address the detailed rules and requirements in filing Form 926 to ensure compliance is met.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
The Purpose of Form 926
- Ensure Taxes on Transfers of Property by U.S. Persons to Foreign Corporations Are Paid
- Prevents U.S. Persons From Avoiding Taxes
- Basics of International Taxation
International Taxation Basics
- Complexity of Form 926
- Terms and Definitions
- Basic Concepts
Changes From Temporary to Proposed Regulations
- Eliminating Goodwill, Narrowing Definitions
- Recognizing Income Under IRC 936 Regulations
- No Favorable Treatment of Intangibles
Form 926 Section-By-Section
- Purpose
- Requirements
- Exceptions
Form 926 Section-By-Section
- Cash
- Types of Property
- Additional Requirements
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on August 18, 2022.
Call 1-866-352-9540 for further credit information.
- AIPB 1.5
- This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Jack Brister
Consultant
- Managing member and founder of International Wealth Tax Advisors
- Over 30 years of experience in forensic accounting, international tax and tax law consulting
- Formed International Wealth Tax Advisors (IWTA) in 2015 after leading the international tax division at Deloitte and Touche
- Specialized in servicing international private clients, foreign businesses desiring to do business in the U.S., and individuals working and living abroad
- Consults extensively for global clients on the state and local tax implications arising when foreign businesses establish operations in the U.S or plan on selling their products to U.S. consumers
- Renowned in both the legal and accounting community as a preeminent expert on foreign trusts and estate taxation
- Former forensic accountant for U.S. Internal Revenue Service’s Criminal Investigation Unit
- Frequently speaks and presents on international tax matters and is a regular contributor to JD Supra, the daily business-to-business publication for breaking news and expert information in legal, financial, business and tax news and compliance for the C Suite
- Member of STEP, NYSSCPA, and EACCNY; board member, Laura Pels International Foundation for Theater
- Can be contacted at [email protected]
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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