Final Chance To Catch The International Taxation And Compliance Seminar

Kat Jennings

“Hot Issues in U.S. International  Taxation & Compliance Seminar” to be held August 15-16 in Boston, MA.

As more U.S. corporations look for tax advantages overseas, the U.S. international tax laws and proposed new regulations will have a greater impact on U.S. businesses and transactions.  These international tax rules affect not only large U.S. and foreign-based multinationals, but also increasingly affect mid-sized and smaller firms, financing transactions, mergers and acquisitions, currency translations and other commercial activity.  As a result, a working knowledge of these international tax rules is importance to a wide variety of tax professionals.  This seminar is designed for those with experience in U.S. tax law and transactions at companies who we have significant cross-border activities.

This intermediate tax planning session is for law and accounting firm professionals who advise clients on structuring cross border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and internal planning and in IRS audits and appeals of international issues; and tax attorneys who want to stay on top of what’s happening in the international tax arena. (Field of Study: Taxes)

Earn Up to 15 CPE/CLE Credits

Monday, August 15, 2016

 

8:00 AM—Registration and Continental Breakfast

8:45 AM—Structuring of Overseas Operations

  • Choosing the right vehicle for investing overseas – branch v. corporation v. hybrid entity v. holding companies – filing the election on Form 8832
  • Understanding and planning with the check the box rules for foreign entities
  • Interrelationship with tax treaty planning, including permanent establishments and limitation on benefits provisions
  • U.S. tax consequences of dual consolidated losses – rules for overall U.S. or foreign losses
  • Impact of U.S. tax reform and BEPS considerations
  • Overview of Proposed Section 385 Regulations

R. David Young, Partner, KPMG LLP, Boston

10:15 AM—Break for Refreshments

10:30 AM—Expense Apportionment Practice Update

  • How expense apportionment affects credits foreign taxes and deduction of U.S. expenses
  • Selecting the best apportionment method – gross-to-gross v. factual apportionment
  • Understanding the rules for interest apportionment – effect of exchange rates on foreign asset bases
  • Strategies for minimizing the apportionment of research, state tax and S,G&A expenses to foreign source income

Joshua A. Leclair, Senior Manager, KPMG LLP, Boston

12:00 PM—Luncheon

1:00 PM—Computing Direct and Indirect Foreign Tax Credit Benefits

  • Obtaining foreign tax credit benefits for foreign withholding taxes – what constitutes a creditable income tax
  • Applying the gross-up formula for foreign taxes
  • Computing the separate foreign tax credit basket limitations – separate limitation loss recapture
  • Applying the related party look-through rules for dividend and interest payments between related CFCs and 10/50 entities
  • How FTC limitations increase the US tax on dividends under Subpart F and Sec. 956
  • Section 901 (m) covered asset acquisition rules

Chris Kelley, Partner, Ernst & Young LLP, Boston
Amber Hu, Manager, Ernst & Young LLP, Boston

2:45 PM—Break for Refreshments

3:00 PM—How the Subpart F Anti-Tax Deferral Rules Operate

  • Identifying CFCs and “U.S. Shareholders”
  • Definition of U.S. shareholder – vote or value ownership
  • Understanding the regulations involving Subpart F FPHC income
  • Working with the branch rules for foreign sales and manufacturing activities
  • Exceptions and limitations on application of the Subpart F rules
  • Affirmative use of Subpart F
  • Avoiding investments in U.S. property by first or lower-tier CFCs
  • Implications of Proposed Section 385 Regulations

Mike Hardgrove, Partner, DLP Piper LLP, Boston

4:45 PM—Meeting Adjourns for the Day

Tuesday, August 16, 2016

 

8:00 AM—Continental Breakfast

8:30 AM—How to Compute Foreign Exchange Gain (Loss)

  • Translation v. transaction gain (loss) – determining the functional currency for QBUs under Sec. 985
  • Determining the character and source of Sec. 988 transactions
  • Translation rules for foreign taxes and earnings and profits under Sec. 986
  • Computing foreign exchange gain (loss) on remittances involving branches and foreign disregarded entities under Sec. 987

To Be Announced, Executive Director, Ernst & Young LLP, Boston

10:00 AM—Refreshment Break

10:30 AM—Tax Reporting for Foreign Operations and Activities

  • Identifying foreign source income from branches and other pass-through entities
  • Understanding the functional currency concept of QBUs – translation of income and Balance Sheet items, E&P and foreign taxes
  • Preparing Form 5471 – analyzing the income statement and balance sheet for Subpart F and transfer pricing adjustments
  • Tracking Earnings & Profits on Form 5471 for foreign dividend and gross-up calculations
  • Disclosing foreign bank accounts on FinCen 114 and other FATCA reporting requirements
  • Review of key U.S. international tax reporting forms – Form 926, 1118, 8838 and 8858
  • Preparation of Form 8886, Schedule M-3 and Schedule UTP for reporting significant book-tax differences
  • Identifying PFICs and preparing Form 8621

Chris Sandry, Senior Manager Ernst & Young LLP, Boston
Caitlin Ball, Senior Manager, Ernst & Young LLP, Boston

12:00 PM—Luncheon

12:45 PM—Transfer Pricing Developments

  • Impact of IRS administrative changes on transfer pricing, APAs and Competent Authority cases
  • Developments in cost-sharing, intellectual property and regulatory developments
  • Update on BEPS and transfer pricing
  • Proposed country by country reporting regulations, changes to
  • Section 482 aggregation rules and the treatment to outbound transfer under sections 367 and 721

Kevin Burke, Partner, Ernst & Young LLP, Boston

2:15 PM—Refreshments Break

2:30 PM—International Mergers and Acquisitions under Sec. 367

  • Acquisition of foreign targets
  • Application of U.S. targets with foreign subsidiaries and foreign multinationals acquiring U.S. targets
  • Using cash offshore to fund an acquisition of a U.S. target
  • Working with the new rules for the transfer of foreign tangible and intangible assets – Secs 367(a) and 367(d)
  • International stock transfers and inversions under Sections 367(a) and Section 7874
  • Application of Sec. 367(b) to inbound and foreign-to-foreign stock transfers – deferral of negotiation of Sec. 1248 E&P
  • Application of New Proposed Section 385 Regulations to intercompany debts

Mike Hardgrove, Partner, DLP Piper LLP, Boston

4:00 PM—Conference Concludes

Register Now!

Conference Location

 

DLP Piper LLP

33 Arch Street, Boston, MA 02110

(617) 406-6000

Hotel Accommodations are at your discretion, we suggest:

Langham Hotel

250 Franklin Street, Boston, MA 02110

(617) 451-1900

Club Quarters Boston

161 Devonshire Street, Boston, MA 02110

(617) 357-6400

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Kat Jennings, CEO
TaxConnections
858.999.0053
kat@taxconnections.com

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1 comment on “Final Chance To Catch The International Taxation And Compliance Seminar”

  • This seminar looks fantastic! Unfortunately, I discovered it only today and cannot be present on such short notice. Is it possible to simply purchase the course material? Please be sure to let me know when you might be organizing another set of sessions. Best!

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