Ms. Brent is experienced in all phases of the U.S. tax amnesty programs for taxpayers with high income tax liabilities, and devises effective outcomes for complex matters in the context of changing regulations and criteria within the international tax amnesty life cycle.
Ms. Brent identifies eligibility factors and risks unique to each client to ensure a favorable selection of the several IRS initiatives, OVDI, OVDP, Streamlined Domestic/International, Transition, or Opt-Out program or program phase. Pre-selection, Ms. Brent provides assessment of international tax treaty/U.S. withholding nexus, complex statute of limitations tolling, Form 872 extensions, tax provisions in entity agreements, penalty computations, pre-contact/post-contact eligibility, potential for criminal investigation, subpart F transaction for eligibility elimination based on avoidance, and potential additional income from subchapter K, subchapter C, and Form 8621 passive foreign investment sources, and evaluates the applicability of Form 8938 foreign financial asset reporting, Form 5471 foreign corporation information, Form 3520 transactions with foreign trusts or foreign gifts, FinCEN 114 reporting, and Currency and Foreign Transactions Reporting Act requirements.
Ms. Brent also manages all types of submissions, and ensures timeline compliance, delivering well-developed presentations during the deadline-driven information document request (IDR) phase. Ms. Brent builds client credibility with IRS officers and agents by developing content for swift reply to their queries, and by tracking IRS delays for assertion of taxpayer rights.
For longer cycle programs, Ms. Brent evaluates revenue agent response to unique facts presented for assessment of potential new tax implications in the context of business objectives and changing regulations. Where the taxpayer is a non- or dual citizen, Ms. Brent has developed the position of culture-specific tax compliance in the context of a diverse legal, international platform.
Ms. Brent’s work mitigates exposure risk, and identifies alternate methods to manage IRS escalation, and ensure compliance with IRS determinations. Her analyses have contributed to reconciliations resulting in extreme penalty reductions, protection from criminal liability, and favorable terms for resolving civil tax and penalty obligations.
Her further experience includes litigation with the Department of Justice, Circular 230 and Professional Ethics issues, and State Voluntary Disclosures.
- The University of Baltimore School of Law, LL.M. Taxation Candidate
- The University of Baltimore School of Law, J.D.
- The University of Hawaii, Bachelor of Arts in Political Science
- International Tax / FATCA
- FBAR Civil Litigation
- IRS Voluntary Disclosures and Amnesty
- Federal and State Tax Litigation
- Offshore Bank Account and Foreign Asset Disclosures