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Self-Study Courses

International Tax Practice, Procedure, and Controversies

2 CPE Credits $41.00/credit hour
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International tax enforcement has become an increasing priority for the IRS as cross border transactions, foreign information reporting, and offshore investments continue to expand. While many tax professionals are comfortable navigating domestic examinations, international audits involve specialized procedures, expanded information gathering tools, and heightened penalties that can significantly increase taxpayer risk if not managed properly.

This online course provides a practical, behind the scenes look at how the IRS approaches international tax compliance, examinations, and controversies. Taught by former IRS Chief Counsel (International) attorney Robert Misey, the program explains the organizational structure of IRS international divisions, the types of international issues drawing audit attention, and the tools used by International Examiners to obtain information from taxpayers and third parties.

Participants will also explore strategies for managing international tax controversies from initial examination through Appeals and, when applicable, the Competent Authority process. Designed for professionals advising clients with cross border activity, this course equips attendees with the insight needed to anticipate IRS actions, ensure proper compliance, and effectively represent clients during international disputes.

Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2029 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

Publication Date: July 2026

Designed For
This course is designed for tax and accounting professionals who work with international clients or cross‑border transactions and need to understand how the IRS conducts international examinations and resolves disputes.

Topics Covered

  • Overview of IRS international organizational structure
  • International examinations and audit focus areas
  • IRS information‑gathering tools and enforcement mechanisms
  • Offshore compliance and information reporting considerations
  • Conclusion of international examinations and Appeals procedures
  • Competent Authority procedures and treaty‑based dispute resolution
  • Best practices for managing international tax controversies

Learning Objectives

  • Identify the organizational structure of the IRS international divisions and their enforcement roles
  • Recognize international tax issues that commonly trigger IRS examinations
  • Evaluate the information gathering tools used by IRS International Examiners
  • Confirm accurate filing of required international information and reporting forms
  • Evaluate an international tax controversy from examination through the IRS Appeals process
  • Apply Competent Authority procedures to resolve cross border tax disputes when appropriate

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.
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