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WHY DO I OWE TAX WHEN IT'S NOT MY MONEY? WITHHOLDING PAYMENTS TO FOREIGN PERSONS

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CPE Processing Fee$10.00
Webinar TranscriptionN/A
Presentation Length Hour(s)1.0 hour
CPE Credits 1.0 hour
Subject Area 1.0 - Taxes (Federal Tax Update)
CE Credits 1.0 hour
Course Id# - HURS9-U-00490-19-S
Course LevelBasic
Instructional MethodQAS Self-Study
PrerequisitesNone
Advance PreparationNone
Recorded DateJune 20, 2019
Date OfferedAugust 7, 2019
Expiration DateAugust 7, 2020
Who Should AttendCPA - small firm
CPA - medium firm
CPA - large firm
Enrolled Agent
Other
Series: International Focus, Taxes, Enrolled Agents, NYU 11th Annual Tax Controversy Forum, Tax Controversy
Course Description

Taxpayers who make payments of certain US-source income to foreign persons must comply with certain withholding and reporting requirements. The IRS recently announced an LB&I compliance campaign to examine taxpayers who make such payments but do not withhold, pay, and/or report as required.

This panel explains who is a withholding agent required to withhold tax on payments to foreign payees, some of the surprising ways in which they can become liable for tax due on money they paid out to others, and how the IRS is pursuing them for payment. Also discussed are the main impact and requirements of the Foreign Account Tax Compliance Act for withholding agents.

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Learning Objectives

  • Identify regulations related to foreign entities and their U.S. tax withholdings.

20
Handout Materials
Presentation Slides
Review Questions
Review Questions
QUESTION 1: 0:16:00 minutes
QUESTION 2: 0:33:00 minutes
QUESTION 3: 0:48:00 minutes
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Christopher Shott

IRS
Attorney, Office of Chief Counsel, Large Business & International Division

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Christopher Shott joined the IRS Office of Chief Counsel, LB&I Division in Manhattan in 2008.  Since 2011 Mr. Shott has focused his practice on information reporting and withholding working closely with Associate Chief Counsel International to provide legal assistance to the Foreign Payments Practice on various Chapter 3 and 4 issues.  Mr. Shott also provides substantive legal assistance to examination teams conducting withholding examinations.

Michael Mattaliano

Ernst & Young, LLP
Senior Manager
michael.mattaliano@ey.com

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Michael is a Senior Manager in Ernst & Young LLP’s Tax technology and Transformation team within the Financial Services Organization.  Michael focuses on the interpretation and implementation of IRS regulations.  Prior to joining the firm he was responsible for the implementation of FATCA at a broker/dealer.  Before industry, Michael was an associate with a boutique law firm focusing on tax controversy.

Kimberly A. Schoenbacher

IRS
Acting Director, Field Operations (Foreign Payments Practice Area)

(212) 298-2027

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Timothy Mulvey

Deutsche Bank
Director & Tax Counsel

Tim joined Deutsche Bank in 2012 and is currently the Bank’s FACTA and Qualified Intermediary Responsible Officer and heads the Indirect and Operational Tax group.  Tim also oversees the Bank’s tax controversies including its withholding tax audits.  Prior to joining the Bank, Tim was Counsel at White & Case LLP and an attorney with the Office of Chief Counsel in Manhattan.

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About Our Presenter

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For nearly 85 years, the NYU School of Professional Studies has been a deeply respected institution of higher education grounded in applied learning. It has served as a source of empowerment for individuals from NYC, across the country, and worldwide who aspire to become the next generation of leaders and innovators of industry.

Throughout its rich history, NYUSPS has met the needs of the students and the professional communities it serves. From its early years of training returning World War II veterans to fulfill the nation’s urgent need for skilled technical workers, it has evolved into a professional education powerhouse that offers 19 graduate degrees, 13 bachelor’s degrees, four associate’s degrees, and a plethora of non-degree courses