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2 IRS CE/CTEC/NASBA CPE*
Entity classification is one of the most fundamental—and most frequently misunderstood—areas of international tax compliance. A single missed or incorrect election can change the entire tax posture of a client, triggering unexpected filing obligations, exposure to penalties, and unintended tax consequences under regimes such as Subpart F or GILTI.
2 IRS CE/CTEC/NASBA CPE*
A practitioner's first decisions on an exam happen before the first IDR is answered — often before the client has finished reading the notice. Type of contact (correspondence, office, or field), what triggered selection, the return's exposure points, and the client's recordkeeping posture all shape what representation should look like. With 2025 enforcement priorities continuing to shift — staffing realignments after the IRA funding pullback, sustained correspondence-exam volume on Schedule C and refundable-credit returns, renewed focus on high-income individuals and large ...
2 IRS CE/CTEC/NASBA CPE*
Audit Reconsideration — It Isn't Over Until We Say It's Over A client walks in with an assessment from an audit they didn't respond to, didn't understand, or lost without representation. The 90-day window is gone. Collections is moving. The question isn't whether the original result was right — it's whether you can reopen it, and what it takes to get a different answer the second time around.

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The International Tax Conference returns in 2026 for another dynamic gathering of experienced international tax professionals. Stay tuned for dates, location details, and registration information!

Discover how Tax Practice Pro has become a trusted source for high-quality live and on-demand CE/CPE, and meet the team of speakers who bring real-world expertise to every course.