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Enrolled Agent
Given the complexity associated with international tax reporting forms—and the relative emphasis by the IRS to ensure reporting requirements are met—increasing numbers of taxpayers are being penalized. While circumstances and facts influence whether an assessment will be reduced or eliminated, understanding the appeal process and relevant standards (including potential exceptions) greatly increases your chances of a positive outcome. This program will cover penalty focus, heightened IRS penalty imposition, and other considerations relevant to the assessment process.
Learning Objectives:
- Recognize the increase in the number of international tax reporting penalties
- Identify potential exceptions that will help reduce or eliminate penalties
- Summarize the current IRS penalty focus and other considerations relevant to the assessment process
Patrick McCormick, JD, LLM
Rimon PC
Partner
[email protected]
(215) 630-0861
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 CPAacademy.org, 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.
- To receive CPE credit, you must register for the webinar before it starts.
- CPE is available to all eligible participants within 24 hours of each webinar.
- To receive CPE for multiple attendees, at least one person must sign up for the webinar. The post-webinar email contains a link to instructions for the proctor letter. Alternatively, you may log in to your account following the webinar and click on the MY ACCOUNT button to find a link to instructions. For paid courses, payment needs to be made for each attendee before credit will be issued.
NASBA Approved
CPAacademy.org (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222
EA Approved
CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.
CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222
About Our Presenter
Rimon's consistent excellence, commitment to the community, and innovation have been internationally recognized, including by Harvard Law School, Stanford Law School, Chambers, Best Lawyers, Super Lawyers, the Financial Times Innovation awards, the Atlantic, the American Bar Association's Legal Rebels, the Economist, the Recorder, and many more.
Rimon’s clients range from cutting-edge technology startups to financial institutions and Fortune 100 companies.
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