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    Networking Seminars Inc.

    445 Park Avenue, 9th Floor

    New York, NY 10022


    Get Social

    November 11, 2014 - New York, NY

    This seminar will discuss in detail foreign base company sales income, foreign personal holding and services income, computing E&P,  foreign tax credit consequences of recognizing Section 1248 and the new substantial contribution contract manufacturing regulations. We will also review reporting issues for CFCs and disregarded entities.  The goal of tax executives is to comply with U.S. tax law while maintaining the lowest effective tax rate.

    This seminar is for corporate tax, finance and accounting executives including tax managers, tax directors, tax specialists, controllers, CPAs, CFOs, as well as, corporate counsel and tax attorneys. There is no advance preparation or pre-requisites for this basic level group live seminar.  Please find the Registration Form below or call 877.500.1510

    Earn 7.5 CPE and 7.5/6.25 CLE Credits (50/60 minute State)

    TUESDAY, NOVEMBER 11, 2014

    8:00 AM Registration and Continental Breakfast

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

    • What is a controlled foreign corporation (CFC)?
    • Basic mechanics of subpart F
    • Overview of subpart F income definition
    • Exceptions to subpart F income definition, including the earnings and profits (E&P) limitation, de minimis exception, full inclusion rule and high-tax exception
    • Affirmative use of subpart F
    • Calculating the Section 960 credit for deemed inclusions
    • Treatment of previously taxed income (PTI) under § 959

    10:30 AM Refreshment Break

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

    • Overview of FBCSI (Section 954(d)(1) & Section 954(d)(2) – Branch Rule)
    • Contract Manufacturing Regulations
    • Substantial Contribution
    • T.D. 9563 Guidance Regarding FBCSI
    • Examples of Branch Rule
    • Procedural Issues
    • Internal Revenue PLRs related to FBCSI

    12:00 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

    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

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

    • Reducing risk and increasing tax savings with foreign Earnings and Profits (E&P) accounting method changes
    • New Proposed GRA compliance regulations
    • Revised IRS Form 5471 and instructions
    • Revised IRS Form 8858; Schedule G Changes and Dual Consolidated Losses

    5:00 PM Seminar Concludes 


    Executive Conference Center
    1601 Broadway, 8th Floor (at the corner of 48th Street)
    New York, NY 10019

    Hotel accommodations are at your discretion, we suggest:
    Crowne Plaza Manhattan
    1605 Broadway
    New York, NY 10019
    Reservations: (212) 977-4000


    Fill in the Form Below and Submit
    Register by phone by calling: 877 500 1510

    Register and pay now with debit or credit card.  Select number of registrants, click on the Pay Now button, and add registrant and card information.  To pay by American Express, Mastercard, Visa or Discover, please click on the “Don’t have a PayPal Account” link pay securely with a credit or debit card.

    Foreign Tax Credits/CFCs & Subpart F Income

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