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International Tax: Tax Crimes and Criminal Exposures

INTERNATIONAL TAX: TAX CRIMES AND CRIMINAL EXPOSURES

Cost Free
Presentation Length 1.0 hour

Recorded DateSeptember 30, 2022
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

When a taxpayer fails to meet reporting requirements, a question which very often arises is whether a taxpayer's failure is sufficient to create criminal tax exposures. Where any type of exposure exists, it is critical to assess the level of exposure—both for purposes of client protection and in the context of how it impacts retroactive disclosure avenues. This program will cover the most relevant criminal tax exposures for taxpayers in an international context, with specific focus on tax evasion and FBAR penalties. The program will also cover how to properly disclose failures by taxpayers with criminal exposures, including using the voluntary disclosure program.

Learning Objectives:


  • Distinguish whether a taxpayer failure is sufficient to create criminal tax exposures

  • Identify the most relevant criminal tax exposures in an international context, specifically tax evasion and FBAR penalties

  • Recognize how to properly disclose taxpayer failures, including using the IRS’s voluntary disclosure program
     

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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.
 

About Our Presenter

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McCormick Tax was established in 2022 to serve clients worldwide – no matter their size – on any and all needs in the United States international tax context. Our clients range from multi-billion dollar business enterprises to cost-sensitive startups, high-net-worth individuals to those with lower net worths but discrete (and often complex) international tax needs. Our firm’s founder – a non-accountant international tax attorney - has previously served as a partner (exclusively focused on international tax work) at an AmLaw200 law firm, a boutique tax, trusts and estates law firm, and a tax-focused accounting firm, giving extensive experience both with every aspect of international tax rules and every type of client with international tax needs. Transitioning from a large firm to an independent practice has also enabled our firm’s practitioners to significantly reduce their hourly billable rates – creating efficiencies for our clients and allowing us to work with clients of all sizes.

Our firm covers every aspect of United States international tax, trusts, and estates rules; we also assist our clients on more domestic-oriented United States tax needs. We work directly with clients; we also serve as “outsourced international tax counsel” for accounting, law, and advisory firms around the world. In that role, we assist wherever beneficial with those firms’ client needs in the international tax context, allowing those firms to hang onto clients/continue to work with those clients rather than losing them to firms with internal international tax teams. Our firm’s independent status gives us enormous flexibility in how we structure representations, ensuring we can serve in optimal fashion for whatever client needs arise.