IRS International Tax Controversies: Procedural and Substantive Issues Webcast | 4193035A

Date :
May 23, 2019 11:00 AM - 1:00 PM
Location :
Facility :
Webcast Rebroadcast
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CPE Credits :
CPE 2.00, MCLE 1.50, IRS-TX 2.00, CTEC-TX 2.00
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The IRS has tripled its number of international examiners and has aggressively audited international tax issues, making it more important that taxpayers with an international tax issue be prepared to defend their position on audit.

Misey draws upon his experience at the IRS Chief Counsel (International) and his time working with multi-industry clientele to help attendees navigate today's international tax controversy landscape and be able to respond to and resolve IRS international tax audits.

Formerly titled: International Tax Controversies With The IRS: Procedural and Substantive Issues

Materials are provided as an ebook.


  • Identify international tax issues the IRS is scrutinizing.
  • Determine and explain the U.S. international tax audit process.
  • Recognize opportunities for audit resolution.

Major Subjects:

  • IRS tools to obtain information in an international audit, including information from foreign countries.
  • Dealing with IRS requests for foreign site visits.
  • Procedural tools for taxpayers to eliminate double taxation, such as the competent authority process.
  • Tips and traps of dealing with the IRS on audit issues, such as foreign tax credits, transfer pricing and Subpart F.

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Designed For:

CPAs and financial professionals.


Robert J. Misey, Jr, Esq.
Robert Misey is a shareholder with Reinhart Boerner Van Deuren s.c. He practices in the areas of international taxation and tax controversies. His previous experience includes nine years as an international trial attorney for the IRS in San Jose and in Washington, DC where he tried 21 Tax Court cases and served on the industry programs for both the athletics and entertainment industries and the manufacturing industries. He also led the international tax group for a region of a Big Four accounting firm. Misey received his bachelor’s degree from the University of Kentucky, his juris doctor and master of business degrees from Vanderbilt University, and his master of laws in taxation from Georgetown University. He is a co-author to the treatises U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure, and a member of the bar in California, Kentucky and the District of Columbia.
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