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Enrolled Agent
International clients—individuals or corporations with operations abroad or foreign investors with operations in the U.S.—are increasingly facing challenges as to their international tax obligations. Usually, a foreign tax administration or the IRS imposes tax deficiencies based on their international tax obligations. Domestic mechanisms such as a petition with the Tax Court or a challenge on District Court are available.
However, more selective alternatives are available and may be beneficial for the taxpayer. One of these alternatives is the Mutual Agreement Procedure (MAP) under which the taxpayer can invoke the protection of a tax treaty to submit his tax case to review of tax administrations of both the U.S. and the foreign jurisdiction. This webinar will identify when the MAP applies, how to file a petition for a MAP, its benefits, and possible outcomes.
Learning objectives:
- Identify alternative dispute mechanism solutions for international clients
- Determine applicability of a MAP for U.S. clients with international operations
Fernando Juarez, LL.M. EA
Freeman Law, PLLC
International Tax Principal
fjuarez@freemanlaw.com
(855) 676-1040
Fernando Juarez, LL.M. EA, is an International Tax Principal with Freeman Law, PLLC. He advises on complex U.S. and international tax planning. His practice focuses on domestic and cross-border transactions. He is also experienced in voluntary disclosures, FBAR, and global compliance.
Fernando’s tax planning expertise extends to Fortune 500 companies, family offices, and medium & small businesses. His primary areas of expertise include inbound structures for international investors and outbound tax planning for U.S.-based companies. He is a frequent speaker at conferences involving tax topics in the U.S. and around the world. Recent speaking engagements include the Organization for the Economic Cooperation and Development (OECD) in Paris, France, the Tax Executives Institute in Houston, the Start-Up Week in San Antonio, and the Hispanic Chamber of Commerce in Texas. Fernando has published multiple tax articles with international editors such as Thomson Reuters and the International Bureau of Fiscal Documentation (IBFD) in the Netherlands.
Fernando received his law degree from the Escuela Libre de Derecho in Mexico City and holds a Master’s in Laws from Stanford Law School, where he served as the first Hispanic Chair of the Stanford Tax Club. He is licensed to provide tax advice in the U.S. and Mexico.
Currently, he is a National Reporter for the Observatory for the Protection of Taxpayer’s Rights by the IBFD. Until 2020, he served as the Secretary of the International section of the San Antonio Bar Association.
Bar Admissions/Licensing: Mr. Juarez is licensed to practice law in Mexico and is licensed to practice before the Internal Revenue Service.
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