FIRPTA Gone Wrong: Misapplied Payments and Practitioner Response
FIRPTA withholding is often straightforward in theory—but in practice, it frequently breaks down. Payments are misapplied, Forms 8288 and 8288-A are processed incorrectly or delayed, and practitioners are left trying to reconcile transactions that no longer match IRS records. When this happens, the issue is no longer compliance—it is resolution.
This program focuses on how practitioners respond when FIRPTA withholding goes wrong. Participants will review the core framework under IRC §1445, including withholding requirements, reporting obligations, and the roles of the parties involved in a transaction. The emphasis, however, is on real-world problems: identifying misapplied or missing payments, understanding why these issues occur, and determining how to fix them.
The program will walk through practical strategies for tracing payments, resolving discrepancies with the IRS, and reconstructing transaction records when documentation is incomplete. Participants will also learn how to manage client expectations, coordinate with withholding agents and closing professionals, and address delays in processing Forms 8288-A.This is a practical, problem-focused program designed for practitioners who are dealing with FIRPTA issues after the transaction has closed and the numbers do not tie.
Learning Objectives (NASBA)
Upon completion of this program, participants will be able to:
-Identify FIRPTA withholding requirements under IRC §1445, including the roles of withholding agents and reporting obligations.
-Determine common causes of misapplied or uncredited FIRPTA payments and recognize discrepancies in Forms 8288 and 8288-A processing.
-Apply procedures for tracing and reconciling FIRPTA withholding payments with IRS records.
-Evaluate available corrective actions and strategies for resolving payment issues with the IRS.
-Assess practitioner responsibilities in managing documentation, client communication, and coordination with third parties during FIRPTA issue resolution.
Only available for TPP unlimited CE subscribers.
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*Self-Study recording not available for NASBA CPE credit.
IRS Program #: 7Q3WU-T-00888-26
CTEC Course #: 6248-CE-00234
Rita Ryan
,
Esq., LLM
Rita Ryan is the Founder of RRITS and a seasoned Tax Attorney with more than 18 years of experience advising clients on cross-border personal/business taxation, international investment structuring, multi-jurisdictional estate planning, and U.S. tax compliance obligations arising from global activities and holdings. She is widely regarded for her ability to navigate complex international tax regimes and translate evolving regulatory requirements into practical, strategic guidance.
In addition to her client-facing work, Rita serves as a trusted advisor to fellow tax professionals, providing specialized support in identifying international reporting obligations, advising on complex filings, and reviewing workpapers and forms to ensure technical accuracy in an increasingly dynamic international compliance environment.
Prior to founding RRITS, Rita served as Chief Financial Officer and Head of Private Client Services at M+, where she focused on integrated tax, business, and wealth preservation planning for high-net-worth business owners and their families. Earlier in her career, she founded and led Wolf & Co.’s International Tax Services Practice, advising both individuals and entities on the tax planning and compliance aspects of international ownership structures. Rita began her legal career in private practice as an Associate Attorney at Vacovec, Mayotte & Singer, LLP, concentrating on international and domestic taxation, estate planning, and tax controversy matters.
Rita is also an Adjunct Professor in the Graduate Tax Program at Boston University School of Law, where she co-founded and co-teaches the course Foreign Information Reporting and Withholding. In addition, she regularly teaches advanced international tax topics for Tax Practice Pros, LumiQ, and the National Association of Enrolled Agents, contributing to the education of practitioners nationwide.
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