Intermediate U.S. International Tax Update

June 7 - 8, 2017 in San Jose, CA

Early Registration: $1295 (before May 6th) Registration: $1495 Attend Introduction to U.S. International Tax & Intermediate International Tax Update Early Registration: $2290 (before May 6th) Regular Registration: $2490 Groups of 2 or more Save $200 off each registrant

As global businesses expand into more regions, the international tax laws of the U.S. impact a greater percentage of 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, and other commercial activity.  As a result, a working knowledge of these international tax rules is of paramount importance to a wide variety of tax professionals.

This intermediate level group live seminar is designed for corporate tax executives, tax counsel, accounting firm professionals and who advise clients on structuring cross border transactions, and on international tax planning and controversy matters; tax professionals involved in cross-border and internal planning, in FIN 48 determinations and in IRS audits and appeals of international issues; and government attorneys who want to stay on top of what’s happening in the international tax arena. There is no advanced preparation but an introductory course or its equivalent is recommend prior to attending.This seminar is non transitional which is appropriate for experienced attorneys. Field of Study: Taxes

Earn Up to 15 CPE/CLE Credits

Wednesday, June 7, 2017

8:00 AM - Registration and Continental Breakfast

8:30 AM - Overview of Subpart F – Focus on Sections 951, 954(a)/(b) & 959

Zey Nasser, Senior Manager, Ernst & Young LLP

9:45 AM - Refreshment Break

10:00 AM - Foreign Base Company Income – Section 954

Dustin Coscarart, Senior Manager, Deloitte Tax LLP

11:00 AM - Section 956 Investments in United States Property

Zey Nasser, Senior Manager, Ernst & Young LLP

12:15 PM - Networking Luncheon

1:00 PM - Direct & Indirect Foreign Tax Credits

Indhira Demorizi, Senior Manager, Deloitte Tax LLP

2:15 PM - Refreshment Break

2:30 PM - Section 904 Limitation

3:45 PM - Sections 861-865 Income Sourcing & Expense Allocation     

Sergei Mytko, Partner, Alvarez & Marsal Taxand, LLC

5:15 PM - Conference adjourns for the day

Thursday, June 8, 2017

8:00 AM - Continental Breakfast

8:45 AM - Transfer Pricing - Inbound & Outbound including BEPS

Darron Lo, Director Transfer Pricing National Office, Moss Adams LLP

10:15 AM Coffee Break

10:30 AM - Dual Consolidated Loss Limitation

12:00 PM - Lunch

1:00 PM - Outbound Asset Transfers to a Foreign Corporation – Sec. 367(a) & (d)

Stephen Bates, Partner, Ernst & Young LLP

2:15 PM - Foreign Mergers & Acquisitions – Section 367(b) including Section 1248              

3:30 PM - Conference Concludes

Conference Location

Ernst & Young Training Center, 303 Almaden Boulevard, San Jose, California, 95110, USA TEL: 408-947-5500

Hotel Accommodations: The Hilton San Jose, 300 Almaden Boulevard, San Jose, California, 95110, USA TEL: 408-287-2100