Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2028 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
In the right circumstances, a timely filed "check-the-box" election on a Form 8832 for a business entity can offer significant tax benefits to U.S. taxpayers. For example, a company may use foreign income taxes paid as a credit to eliminate double taxation. A check-the-box election must be properly filed within 75 days of its effective date on a Form 8832. Although ostensibly a simple looking form, an improperly filed Form 8832 can have a deleterious tax effect.
Presented by former IRS attorney and noted international tax advisor, Robert J. Misey, Jr., J.D., LL.M., M.B.A. and author of the treatise, U.S. Taxation of International Transactions published by CCH, this practical two-hour online CPE course will provide detailed guidance on the procedure of making a check-the-box election — both on a timely and delinquent basis — and the practical tax planning implications for both domestic and international entities. The expert presenter will discuss the technical guidance provided by the IRS along with their experience in how the IRS applies the rules, focusing on the immediate tax consequences of the election. All professionals in public practice and in industry involved with cross-border business tax planning and compliance matters will benefit from this helpful course. Course materials will include a sample completed Form 8832 and 8858 prepared by Robert Misey.
Publication Date: October 2025
Designed For
Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys and other financial advisors who work with and advise clients with cross-border activities and tax issue
Topics Covered
- Fundamentals of “checking the box”
- Timing of check-the-box elections
- Domestic tax implications of checking the box
- International tax implications of checking the box
- Completing a Form 8832 "Check-the-box election"
- International tax compliance for a "checked" entity - Form 8858
Learning Objectives
- Explain the tax law, requirements and procedures for making check-the-box elections
- Identify opportunities where making a check-the-box election will save taxes
- Explain how to make a Form 8832 Check-The-Box Election
- Explain delinquent Check-The-Box Elections
- Explain how to complete a Form 8858
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructor
Robert J. Misey
Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and Chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment.
For U.S. based multinationals, Rob helps clients maximize foreign tax credits and take advantage of export benefits to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob's significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts.
Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Four accounting firm.
Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs in numerous states and foreign countries. He has published numerous articles and is a co-author to treatises, U.S. Taxation of International Transactions and Federal Taxation Practice and Procedure, both published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system.
Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar.