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  1. PS.

    Just for yucks, go to the IRS website and on their “forms and instructions” page search for forms with the word “foreign” in the “title”.

    The list runs to 3 pages.

    And don’t forget the good ol’ IRS pubs:

    54 (the classic)

  2. Esp. for citizen/resident clients in the USA:

    8802 (application for US residency certification. Often the first step in obtaining refunds of excess withholding on certain foreign investments.)

    673 Statement for Claiming Exemption from Withholding on Foreign Earned Income Eligible for Exclusion(s) provided by Section 911

    Esp. for citizen/resident clients outside USA:

    2555 (Foreign earned income exclusion)
    1116 (Foreign tax credit for individuals)
    8833 (Treaty based return position)
    8621 (PFIC)

    For NRAs:

    8805 (partnership withholding under §1446)

    For Businesses:

    Form 926 (Return by a U.S. Transferor of Property to a Foreign Corporation)

    I’m sure there’s more but these are the ones I see the most.

  3. A few things I’d add. You could start the presentation going from the most common to less common cases. If you want to put some dramatic effect, comment on the FBAR and FATCA. To close, you them with a leave them with a jaw dropper and do a case example of someone like your potential Canadian IRS Felon with a PFIC/FBAR/FATCA nightmare case study example and how much misery they’re in for just dealing with one of those.

  4. Robert,

    This is a good idea.

    Also, I’m thinking that since I only have one hour I will limit my speech to stuff a CPA would need in preparing an individual income tax return.

    The CalCPA Tax Update and Planning Conference is attended by practitioners who are on their own or in smaller firms and I suspect this will satisfy their needs more than a discussion of corporate tax esoterica.

  5. Thanks for the comments and suggestions. Keep them coming.

    If there is some particular problem with a form, please comment about that, too.

    I’ll give you an example: how the &^%(*$$ do you make a Form 3520 and Form 3520-A work when you have a Mexican fideicomiso? There are two possible answers:

    — One: a fideicomiso is not a foreign trust so you don’t have to do a Form 3520 and the fideicomitente (which is always a Mexican bank) does not have to supply Form 3520-A.

    — Two: a fideicomiso is a foreign trust and it does not in any way match the way a fideicomiso ownership interest is acquired and maintained by a U.S. taxpayer.

  6. I’d organize it by the way you’d be a CPA asking the client questions about his International Life. Do you just live overseas or domestic Do you work there, earn an income there? Do you have investments or Asset overseas? Did you receive any gifts property from overseas? etc etc.

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