Scott Michel to Speak on Developments in Offshore Tax Compliance


The 2012 ALI-ABA International Trust and Estate Planning Course will be held at The Ritz-Carlton Toronto, Ontario, Canada from August 23-24, 2012. The course, designed for estate planners, accountants and financial planners with cross-border practices, and trust officers of both U.S. and foreign banks, will include the following topics:

  • Tax and reporting rules relating to foreign trusts and trusts established by foreign grantors, plus the regulations and procedures implementing them
  • Complementary tax regimes affecting foreign corporations with U.S. shareholders
  • Marital planning for the non-citizen spouse
  • "Inbound" and "outbound" grantor trusts
  • Segments on international philanthropy and unique estate planning concerns for Canadian clients

This course will cover audits, investigations, and voluntary disclosures in the U.S. and Canada; changes to taxpayer "voluntary disclosure" policy and procedure in the U.S. and Canada; penalties and statutes of limitation in the international tax area; implications of HIRE/FATCA reporting provisions on U.S. and cross border issues; developments in the U.S. and Canadian information exchange with Switzerland and elsewhere; recent developments with foreign financial account reporting on Form TDF 90-22.1 ("FBAR"); IRS and CRA enforcement policies and their application, including penalty exposure. The course, taught with David H. Sohmer, will start at 3:45 p.m. on Friday, August 24.


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