This course delivers a comprehensive legal deep dive into IRS enforcement practices, penalties, and defense strategies applicable to foreign nationals with U.S. tax exposure, including investors, business owners, high-net-worth individuals, and inbound companies. It equips attorneys, tax advisors, and compliance professionals with the tools to identify, manage, and mitigate IRS enforcement risks—particularly in the context of asset ownership, residency classification, income sourcing, information reporting failures, and cross-border structuring.
Participants will engage in hands-on simulations including IRS audits, penalty defense documentation, non-filer remediation, treaty-based position justifications, and voluntary disclosure strategies. Emphasis is placed on practical application of U.S. tax law, procedural defenses, administrative practice, and strategic interaction with IRS divisions such as LB&I and CI.
Course Objectives
By the end of this course, participants will be able to:
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Identify key IRS enforcement risks affecting foreign nationals.
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Understand penalty regimes under IRC provisions applicable to NRAs.
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Evaluate and apply legal defenses to reduce or eliminate penalties.
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Navigate IRS audit and collection procedures from a foreign-national perspective.
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Prepare legal filings to assert treaty-based positions and compliance waivers.
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Implement corrective actions through streamlined or voluntary disclosure programs.
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Structure future activities to avoid triggering enforcement triggers.
