Monday’s Tax Planning Seminar For CFCs In Philadelphia

Kat Jennings

September 19 is just on the other side of the weekend. There’s not much time left to sign up for this Tax Planning Seminar.

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

Subpart F income is one of the important issues to be aware of when completing Form 5471, but it is also very difficult to determine. According to I.R.C. Section 952, there are several categories of subpart F income. Attend this seminar to learn about CFCs and the subpart f categories and about several exceptions to the categories of subpart F income to reduce taxes.

These international tax planning seminars are for law firm and accounting firm professionals who advise clients on structuring cross border transactions and on international tax planning matters; in-house tax professionals involved in cross-border and internal planning, in IRS audits and appeals of international issues and tax compliance activities. There is no advance preparation or prerequisites for this group live seminar. (Field of Study: Taxes)

Earn Up to 8 CPE/CLE Credits

Monday, September 19, 2016


8:30 AM – Registration and Continental Breakfast

9:00 AM – Overview of Subpart F Provisions – Basic Mechanics

  • Introduction
  • Controlled Foreign Corporations (Section 958)
  • Subpart F Income Definition and Exceptions (Section 952)
  • Investments in U.S. Property (Section 956)
  • Income Inclusion Requirements and Limitations (Section 951)
  • Calculating the Foreign Tax Credit (Sections 901, 902 and 960)
  • Previously Taxed Earnings (Section 959)
  • Sale of a CFC (Section 1248)
  • Affirmative Use of Subpart F

Jaclyn Obeso Kunkel, Senior Manager, KPMG LLP, Philadelphia
Maya Lupova, International Tax Manager, KPMG LLP, Philadephia

10:30 AM – Refreshment Break

10:45 AM – Section 954(d) – Foreign Base Company Sales Income

  • Foreign Personal Holding Company Income
  • Same-country Exception
  • Active Trade or Business Exception
  • CFC look-through – Section 954(c)(6)
  • Active Financing Income Exception
  • Foreign Base Company Services Income
  • Substantial assistance

John C. Crucs, Managing Director, KPMG LLP, Short Hills, NJ
Brad Kinder, Tax Manager, KPMG LLP, Short Hills, NJ

12:15 PM Luncheon

1:00 PM – Overview of Sections 954(c) and 954(e)

  • Foreign Personal Holding Company Income (FPHCI) defined in § 954(c)
  • Look-through Exception § 954(c)(6)
  • Notice 2007-9 – Anti-Abuse Rules
  • Foreign Base Company Services Income (FBCSI)
  • Substantial Assistance Test Notice 2007-13

Phyllis E. Marcus, Director, PricewaterhouseCoopers LLP, Washington, DC

2:15 PM – Refreshment Break

2:30 PM – Computing E&P and Section 1248

  • Calculation of E&P
  • Overview of Section 1248 and calculation of the Section 1248 amount
  • Foreign tax credit consequences of recognizing Section 1248 amount, interaction with Sections 338(g) and 338(h)(16)
  • Application of §367 to §304 Transactions
  • Final Section 1248 Regulations

James K. Sams, Principal at KPMG LLP, McLean, VA

4:00 PM – Reporting Issues for Controlled Foreign Corporations and Disregarded Entities

  • Reporting Issues for Controlled Foreign Corporations (CFCs)
  • Accounting method changes affecting Earnings & Profits
  • Final GRA compliance regulations
  • Updates concerning IRS Form 5471
  • Recent developments in certain areas of the IRS code and regulations with regard to income tax compliance
  • Creditable foreign tax expenditures §1.704-1T
  • Foreign tax credit – credit vs. deduction

Raymond Wynman, Director International Tax, Global Tax Management, Philadelphia

5:00 PM – Seminar Concludes

Conference Location

Regus Conference Facility
1500 Market Street-12th Floor, East Tower
Philadelphia, PA 19102
(215) 246-3400

Club Quarters Hotel
1628 Chestnut Street (At 17th Street)
Philadelphia, PA 19103
(215) 282-5000

Sonesta Philadelphia Downtown Rittenhouse Square
1800 Market St
Philadelphia, PA 19103

Kat Jennings, TaxConnections, CEO and Founder and Advisory Team provides three areas of services: 1) Internationally recognized, retained executive search services for multinational corporations, public accounting firms, and law firms; 2) Introductions of sellers to buyers of small and medium size accounting firms; and 3) Provide brand building and education services that support and prepare accounting firm owners to buy/sell an accounting practice. We focus on educating the journey to sell a practice and how to increase firm revenue prior to any sale. Our program ensures you start years prior to a sale by learning what is expected of you during the selling process, and introducing firm Partners to cross selling opportunities that are easy to implement and reduce your workload at the same time. We introduce you to value added connections to smartly grow revenue in your accounting practice.

Kat Jennings has been retained by organizations worldwide to locate tax professionals with highly specialized tax knowledge and expertise. She has a thorough understanding of the tax business community, with a proven record of stellar performances matching professionals with organizations. Bringing two parties together to work successfully is the art of understanding personalities, cultural fit, expectations by both parties, flexible or inflexible work environments, understanding what drives and motivates each party, and revolves around the personality and ethics of each executive team.

Kat is a widely recognized expert in high level, tax executive search, as well as connecting buyers and sellers of accounting firms. TaxConnections provides and educates small to medium size accounting firms owners and Partners how to prepare and sell their firms so they can build a succession plan for their retirement. With larger firms seeking to acquire smaller accounting practices, there is a real need to help firm owners prepare to be acquired. Most firm owners are unaware they are not ready to sell when they decide to retire. TaxConnections educates firm owners’ what they need to do years in advance of selling an accounting firm practice.
Senior tax executives expect the utmost privacy when being introduced to multinational organizations about a new tax opportunity under consideration. Having said that, companies searching for a new head of tax expecting tax executive candidates to submit their resume through a resume portal, will never see a full slate of outstanding tax executives available due to a candidates’ desire for greater privacy. This is why privacy focused Uber Tax Recruiters consistently outperform in-house recruiters on tax executive searches.

We offer our clients a Performance Retainer Agreement arrangement so their HR department can still recruit and compete with the tax candidates we present on Head of Tax searches. The client pays us a partial fee upfront, and if they find a candidate they deem better than we introduce to them, we forfeit the final fee. Most of the time, they love and prefer our private introductions to tax executive candidates better than what they source through their own resume portals.

When we represent selling/buying small to medium-sized firms, firm owners/partners also demand greater privacy when considering the sale of their practice. TaxConnections provides a safe place to discuss their business needs, elevate their practices’ online reputation, and increase revenue through new streams of business development by outsourcing work and partnering with other firms. Over three decades, we have worked tirelessly to build relationships between firm owners most organizations rarely have access to in the world of tax. There are numerous possibilities you may never have considered previously to bolster the value of your practice and service offerings.

As a globally recognized consultant to multinational organizations, accounting firms, and law firms searching for tax expertise, Kat has been retained by public accounting firms, law firms, and corporations worldwide including Apple Computer, AC Neilson, Accenture, Agilent Technologies, Allergan, Alza, American Express, American Media, Aon, Baker & McKenzie, Barclays Bank, Bechtel, Cargill, Carl Zieuss Vision, Century Aluminum, Chevron, Clorox, Citigroup, Commercials Metals, Constellation Energy, Countrywide, Del Monte, Deloitte Touche, DFS, DLA Piper, E&J Gallo Winery, Electronic Arts, Ernst &Young, Fox Entertainment, Fremont Investments, General Electric,General Motors, Herbalife, Hewlett Packard, Hyatt, Intel, Jones Lang LaSalle, Kimco Realty, KLA Tencor, Koch Industries, KPMG, Levi Strauss, Liberty Mutual, LKQ, Loews, Logitech, Lucas Film, Maersk, McKesson, Nalco, Newell Rubbermaid, Nissan, Oracle, Orbitax, Pacific Gas & Electric, PwC, QAD, SAIC, SanDisk, Sanmina, Sempra Energy, SONY, Synopsys, Ticketmaster, Trimble Navigation, Toyota, Univar, Wal-Mart, Wells Fargo, Vertex, Yahoo, Xilinx, and many more not listed here.
Contact Kat at 858,999.0053 Office/858.232.4415 Cell or to request a private consultation regarding the sale of your practice, adding top talent to your organization, or merging your practice with another firm owner with a book of business. The possibilities are endless; if you have a dream of a new vision for your professional life; we will scout opportunities throughout the market to make it happen.

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