FBAR: Current Legal Developments and Challenges

The Supreme Court has finally granted certiorari to look at the FBAR. Originally enacted in the 1970s, the Bank Secrecy Act’s FBAR provisions have more recently become a prominent source of penalties associated with failures to report foreign accounts.   This panel of experts will discuss the FBAR and related penalty considerations, as well as the prospective challenges and potential implications of a Supreme Court decision in the area.

Learning Objectives:

After attending the session, the participant will be able to:

• Understand current caselaw development and prospective challenges;

•  Identify applicability of civil penalties to common scenarios

Mexico Cross Border: Practical Challenges & Foreign Implications

Foreign investors face multiple tax compliance challenges when entering the U.S. tax system. On the other hand, U.S. investors with foreign assets in Mexico face a variety of tax issues that must be clearly understood to avoid noncompliance. This challenging landscape requires a fresh look at cross-border tax-planning opportunities. This panel will discuss U.S.-Mexico tax planning opportunities in the current environment. 

Learning Objectives:

After attending the session, the participant will be able to:

• Identify opportunities for tax planning on U.S.-Mexico cross-border transactions;

•  Better understand the tax implications of inbound and outbound investments into the United States

Transfer Pricing Updates: Medtronics III

The Medtronic saga continues with the so-called Medtronic III decision. This case presents perspectives on the IRS’s and taxpayers’ use of various transfer pricing methods and provides insights on the approach taken by the Tax Court. This panel, comprised of private practitioners and academic experts in the transfer pricing area, will cover the potential implications of this recent decision.

Learning Objectives:

After attending the session, the participant will be able to:

• Discuss potential challenges presented by the most recent Medtronics case; 

•  Gain an understanding of the issues relevant to a transfer-pricing dispute; 

•  Gain a better understanding of future transfer pricing trends

Crypto Taxation & Beyond: It's Not Just About Taxes

The regulatory approach to cryptocurrency is more relevant than ever.  Tax is a major consideration.  But there are numerous other regulatory and policy considerations.  This panel will discuss current challenges in the crypto arena and associated potential legal and regulatory issues.

Learning Objectives:

After attending the session, the participant will be able to:

• Identify the current tax challenges in the crypto area; 

•  Learn about potential legal and regulatory issues with cryptocurrency; 

• Determine potential areas that could be subject to novel regulatory action

The Corporate Transparency Act: Traps for the Unwary

The deadline for American businesses to comply with the Corporate Transparency Act (CTA) is now January 1st, 2024.  Initially enacted in 2021, the CTA has gone through a slow rulemaking process, leading to the recent issuance of final regulations. This panel will discuss the newly published regulations and the potential challenges that business across the U.S. will face, including the identification requirements established in the CTA for beneficial owners and applicants.

Learning Objectives:

After attending the session, the participant will be able to:

• Identify the concepts and disclosure requirements established in the CTA; 

•  Determine challenges and compliance measures to be taken by the U.S. entities and its beneficial owners to comply with the CTA 

International Tax Planning with the Corporate Alternative Minimum Tax (CAMT)

The Inflation Reduction Act established the new Corporate Alternative Minimum Tax (CAMT). This new tax is applicable for certain businesses and is designed to establish a “minimum” tax on multinational corporations. This panel will discuss the CAMT’s main concepts and their potential impact on U.S. multinationals and the relationship with other international rules.

Learning Objectives:

After attending the session, the participant will be able to:

• Understand the impact of CAMT in U.S. businesses; 

• Identify and determine potential consequences of CAMT on various sections of the Revenue Code

Networking Round Tables

International Penalties and Practical Strategies

Enforcement efforts have given rise to significant civil penalties, including FBAR and information-return penalties.  Join our panel as they discuss developments with respect to civil tax penalties in the international tax context and strategies for addressing those penalties.

Learning Objectives:

After attending the session, the participant will be able to:

• Identify recent international tax enforcement actions through the use of civil penalties; 

• Discuss recent federal court cases that have addressed international tax penalties

Presentation of Featured Speaker

Featured Speaker: IRS Commissioner - The Honorable Charles P. Rettig

Learning Objectives:

After attending the session, the participant will be able to:

• Deliver secure and customized services to meet taxpayer needs;

•  Identify and address the needs of underserved and multilingual communities to improve their ability to participate in the tax system;

•  Provide proactive outreach and education to improve taxpayer understanding of their rights, responsibilities and obligations

Closing Remarks of Featured Presentation

International Framework of Cryptocurrency

The Organisation for the Economic Cooperation and Development (OECD) has taken a leading position in the development of cryptocurrency-related tax policy.  The OECD previously developed issued draft guidance referred to as its Crypto-Asset Reporting Framework, which was opened to public consultation, along with potential amendments to the Common Reporting Standard. This presentation will provide unique insight into the OECD’s soon-to-be-released international framework on crypto. 

Learning Objectives:

After attending the session, the participant will be able to:

• Gain insights into the OECD’s new international framework; 

• Learn about crypto-related policy considerations;

• Identify the requirements of this policy and the potential impact on crypto transactions

Global Tax Deal: LATAM Perspectives

The new OECD tax deal (Pillar 1 and Pillar 2) and the prospective tax reform in various LATAM countries are changing the current tax framework in such jurisdictions. This panel features presenters from Mexico, Brazil and the U.S., and will cover tax developments in their respective jurisdictions, as well as the most pressing foreign tax issues that every tax practitioner must know to properly advice clients on possible tax implications in such countries.

Learning Objectives:

After attending the session, the participant will be able to:

• Identify and understand the most current international tax developments in Brazil, Mexico and the potential impact on a U.S. client’s planning;

• Determine the relevant tax issues associated to cross-border investments in certain LATAM jurisdictions and the potential impact of the implementation of the OECD pillars in such countries

Current Tax Issues in the Hispanic Community (Spanish Speaking Panel)

The growing Hispanic community in the U.S. faces tax-related challenges. Those challenges have been addressed actively by the IRS and various organizations across the U.S. This panel will provide insights on the most current challenges that are faced by the Hispanic community and will offer some actions that have been developed across the U.S.

Learning Objectives:

After attending the session, the participant will be able to:

• Detect challenges of providing tax services in the Hispanic community;

• Identify potential organizations and actions that could assist when facing challenging tax situations in the Hispanic community

Closing Remarks