June 15 & 16, 2015 - San Diego, CA

Learn the fundamentals of U.S. international taxation.  This seminar will provide a basic understanding of U.S. international tax codes and tax reporting requirements for U.S. corporations with operations abroad.   The goal of the corporate tax practitioner is to reduce U.S. taxes on foreign income while also complying with Internal Revenue Codes. 

This course is for corporate tax, finance and accounting executives, CPAs, tax attorneys and counsel.  There is no advance preparation or pre-requisites for this group live seminar. This basic level seminar will explain the various aspects of taxation for U.S. multinational corporations. 

Earn Up to 15 CPE Credits and 15/13 CLE Credits (50/60 minute State)

MONDAY, JUNE 15, 2015

8:30 AM - Registration and Continental Breakfast

9:00 AM – Introduction & Overview of U.S. International Taxation

  • Understanding worldwide vs. territorial tax systems
  • Residence vs. activity based tax jurisdiction
  • Taxation of foreign income of U.S. corporations
  • U.S. income and sourcing rules
  • Permanent establishment principles and double taxation
  • Claiming a deduction or credit for foreign income taxes

10:00 AM - Refreshment Break

10:15 AM - Source of Income, Allocation and Expense Apportionment

  • Residence For Taxation
  • Income From Single and Mixed Sources
  • Establishing Foreign Title Passage-The Use of Incoterms
  • Tax Planning to Create or Increase Foreign Source Income
  • The Basic Rules of Allocation and Apportionment
  • The Apportionment of R&E Expenses
  • Asset Apportionment of Interest Expense
  • Tax Planning in Expense Apportionment

12:00 PM – Networking Luncheon 

12:45 PM - The Foreign Tax Credit

  • Key concepts of the foreign tax credit
  • Taxes available for the credit
  • § 901 direct credits
  • § 902 indirect (deemed paid) credits and § 960
    • Tax Pools & E&P Pools
    • § 78 gross-up
  • Foreign tax credit limitation formula
  • Applying the foreign tax credit limitation formula for passive and general baskets
  • § 905 and Redeterminations

2:30 PM – Refreshment Break

2:45 PM Controlled Foreign Corporations (CFCs), Passive Foreign Investment Companies (PFICs) and Subpart F Income

  • What is a Controlled Foreign Corporation (“CFC”)
  • Effect of Voting Agreements on CFC Determination
  • Overview of Subpart F Provision
  • Subpart F Income Definition
  • Exceptions to Subpart F Income Definition
    • E&P Limitation
    • De Minims Exception
    • Full Inclusion Rule
    • High-Tax Exception
    • Qualified Deficit
  • Calculating the Section 960 Credit for Deemed Inclusions
  • Previously Taxed Income

4:15 PM - Earnings and Profits

  • Earnings and profits (“E&P”) generally
  • Common E&P adjustments
  • The steps in preparing an E&P study
  • Preparing a computation of E&P pre-1987
  • Preparing a computation of E&P post-1986
  • Practical issues in calculating E&P
  • The importance of E&P in international tax

5:15 PM - Seminar adjourns for the day

TUESDAY, JUNE 16, 2015

8:30 AM - Continental Breakfast

9:00 AM - Tax Reporting Requirements for Foreign Operations

  • Form 5471, Controlled Foreign Corporations
  • Form 8858, Foreign Disregarded Entities
  • Form 8865, Controlled Foreign Partnerships
  • Form 1118, U.S. Foreign Tax Credits
  • FinCen Form 114, Foreign Bank Account Reporting
  • Form 8833, Treaty Based Return Positions

10:30 AM - Refreshment Break

10:45 AM – Transfer Pricing

  •  Overview of Section 482-The Arm’s Length Standard
  •  Determining The Best Method for Sales Of Products
  •  The Methods: CUP, Resale Price, Cost Plus, Profit Splits and CPM
  •  Comparability factors for CPM
  •  Preparing/Reviewing a Transfer Pricing Study
  •  Multi-Jurisdictional Use of a Transfer Pricing Study

11:45 PM Networking Luncheon

12:30 PM – Income Tax Treaties

  • Doing business Abroad- Overview of Tax and Non-Tax considerations
  • Overview of the Tax Treaty Approach to Double Taxation Relief
  • The Essential Elements of Income Tax Treaties
  • Permanent Establishments
  • Business Profits
  • Withholding Taxes on Source Income
  • Qualifying for Treaty Benefits
    • Accessing Treaty Benefits- Resident Requirement
    • Limitation on Benefits
  • Double Tax Treaty Relief Example

1:30 PM - Cross-Border Mergers & Acquisitions

  • Overview of §367
  • Outbound Transactions — §367(a)
    • General Rule, Exceptions and GRAs
    • Indirect Stock Transfers
    • Section 367(a)(5)
    • Outbound Transfers of Intangibles — §367(d)
    • Inversion Transactions — §7874
  • Inbound Transactions — §367(b)
  • Foreign-to-Foreign Transactions — §367(b)
  • Section 367(e)(2) Liquidations
  • Section 304 and Cash-D Transactions

3:00 PM – Seminar Concludes

Conference Location

Networking Seminars Conference Room
San Diego, CA

Register Now

Cancellation Policy

If you are unable to attend, you will be eligible for a credit to attend a future seminar less a $100 administrative fee. Substitutions for registrants are acceptable at anytime prior to seminar.  You must inform us at less 3 business days prior to the seminar date in order to be eligible for a credit. Credits are valid for one year. No refunds will be granted at any time.  If you have any questions please call 877-500-1510 or email: