October 19 & 20, 2015 - Philadelphia, PA

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.  Download Brochure

Earn 15 CPE Credits and 15/13.5 CLE Credits (50/60 minute State)

Monday, Ocotber 19, 2015

8:30 AM - Registration and Continental Breakfast

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

  • Understanding Worldwide vs. Territorial Tax Systems
  • Resident vs. Activity Based Tax
  • Taxation of foreign income on U.S. Corporations
  • U.S. Income and Sourcing Rules
  • Permanent Establishment Principles and Double Taxation
  • Claiming a Deduction or Credit on Foreign Income

10:00 AM - Refreshment Break

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

  • Residence For Taxation
  • Income From Single and Mixed Sources
  • The Basic Rules of Allocation and Apportionment
  • The Apportionment of R&D Expenses
  • Asset Apportionment of Interest Expense

12:00 AM – 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
  • PFICs

 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

5:30 PM - Seminar adjourns for the day

Tuesday, October 20, 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

12:00 PM - Networking Luncheon

12:45 AM – Income Tax Treaties

  • Doing Business Abroad
  • Purposes of Income Tax Treaties
  • Essential Elements of Tax Treaties
  • Interpreting a Treaty Provision
  • Qualifying for Treaty Benefits
  • Taxes on Source Income
  • Permanent Establishments and Business Profits

1:45 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
1500 Market Street, 12th Floor,
East Tower, Philadelphia, PA 19102

Hotel accommodations are at your discretion, we suggest:

Club Quarters, 1628 Chestnut Street At 17th Street Philadelphia, PA 19103
Rates starting at $154 per night

Sonesta Hotel, 1800 Market St, Philadelphia, PA, 19103 Reservations: 215.561.7500
Rates starting at $239 per night

Register Now - Registration includes publication in electronic format, continental breakfasts, lunches and refreshments


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: