Seminar Publications

Seminar publications are available from our recently held courses at a cost of $195 each.  Below is the list of current books we are offering for purchase. Please click on the Buy Now button below the descriptions to purchuse.  If you wish to pay by check, fill in the form at the bottom of the page and submit.

Accounting for U.S. Income Taxes presentations include:

• Current Tax Provision; Credits and Common Book Tax Differences
• Deferred Taxes
• Valuation Allowances 
• Disclosure Rules
• FIN 48 Tax Contingencies
• Interim Period Taxes
• Deferred Tax as a Liability
• Stock Options and Deferred Taxes
• APB 23 (AC 740.30.25), U.S. International Implications and Foreign Operations

Introduction to U.S. International Tax presentations include:  

• Introduction & Overview of U.S. International Tax
• Source of Income, Allocation & Expense Apportionment
• The Foreign Tax Credit
  
• Transfer Pricing
• Controlled Foreign Corporations, Subpart F Income, and Passive Foreign Investment Companies
• Earnings and Profits
• Tax Reporting Requirements for Foreign Operations
• Income Tax Treaties
• Cross-Border Mergers & Acquisitions
  

U.S. International Tax Update presentations include:   

• Overview of Subpart F - Sections 951 & 959
• Direct & Indirect Foreign Tax Credits and Section 904 Limitation and Legislative Proposals
• Section 987 & 988 - Foreign Currency Branch Gains and Losses
• Domestic Consolidated Losses, Overall Foreign Losses and Branch Loss Recapture Rules
• International M&A Developments

Controlled Foreign Corporations & Subpart F Income presentations include:

• Overview of Subpart F Provisions - Basic Mechanics
• Section 954(d) – Foreign Base Company Sales Income
• Overview of Sections 954(c) and 954(e)
• Computing E&P and Section 1248
• Reporting Issues for Controlled Foreign Corporations and Disregarded Entities 

Foreign Tax Credits presentations include:

•  Overview of the Rules Affecting Foreign Tax Credits and Understanding the Foreign Tax Credit Mechanics: Sections 901, 902, 960 & 903
• Understanding the Foreign Tax Credit Limitation - Section 904
• Understanding the Look-Through Rules Under Section 904(d) (3) and (4)
• Foreign Source Losses and Overall Domestic Losses and their Effect on the Foreign Tax Credit Limitation
• Recent Legislative Developments

U.S.-Canada International Tax Planning presentations include:

• Intercompany Loans and Accounts Receivable
• Earnings Stripping Rules – Section 163(j)
• Branches and Hybrid Branches
• Mergers and Acquisitions – Acquisition of a U.S. Entity
• Transfer Pricing 
• Services Regulations – Reg. Section 1.482-9
• Treaty Developments affecting Canadian Companies
• Foreign Bank Account Reporting
• Mutual Agreement Procedure and Arbitration
• Recent Legislative Changes and Proposals

Tax Planning for the Biotech & Pharmaceutical Industries presentations include:

• Overview of Recent Legislation & Tax Provisions  
• Development & Transfers of Intellectual Property  
• Services Regulations – Reg. Section 1.482-9  
• Cost Sharing RegulationsContract Manufacturing Regulations
• Supply Chain Management 
• R&D Tax Credits & Recent Developments
• International Restructurings

Legal & Regulatory Issues Affecting the Wine Industry presentations include:

• Effectively Negotiating Wine Grape Contracts
• Employment & Labor Law for the Wine Industry – 2012 Update
• Protecting Your Wine Brand
• The Current Legal Landscape for Direct Shipping
• California ABC Regulations – Hot Topics you Need to Know

Inbound Tax Planning presentations include:

• Choice of Entity
• Effectively Connected Income & Permanent Establishments 
• Financing the US Business 
• Life After Out-from-Under
• Foreign Nationals

Transfer Pricing presentations include:

• Overview of U.S. International Transfer Pricing—Key Issues and Hot Topics
• Cost Sharing Today
• Global Treatment of Services Transactions
• Handling an IRS Transfer Pricing Examination
• Transfer Pricing in the BRIC
• Transfer Pricing Documentation
• US Transfer Pricing Legislation
• The New Advanced Pricing and Mutual Agreement Program
• The Future of Transfer Pricing