Thank you to our Conference Sponsor Baker & McKenzie LLP
Introduction to International Corporate Taxation
July 23-24, 2019 - San Francisco, CA
Regular Registration $1395 ; Please use code GRP for Group Registration (3 or more) Save $200 Off Each Registration. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies
Networking Seminars will host its basic level international tax planing seminar to address legislative changes affecting corporate taxation, doing business overseas, tax planning concepts. Ensure that your corporate tax planning is in compliance in today's new tax code after the Tax Cuts & Jobs Act. Though the code is simplified it is also more complex.
Attendees will have the opportunity to engage with our tax practitioners on topics related to understanding tax reform and the practical implications.
This course is for corporate tax, finance and accounting executives, CPAs, tax attorneys and counsel. This basic level seminar will explain the various aspects of taxation for U.S. multinational corporations. There is no advance preparation or prerequisites for this group live seminar. Field of Study: Taxes Earn Up to 13 CPE/CLE Credits
Tuesday, July 23, 2019
8:00 AM - Registration Opens
8:45 AM – Overview, Source of Income, Allocation and Apportionment of Expenses
Worldwide vs. Territorial Tax Systems
Taxation of Foreign Income of U.S. Corporations
Sourcing of Income
Foreign Source Income Separate Groupings
The Basic Rules of Allocation and Apportionment
Asset Apportionment of Interest Expense
Apportionment of Research & Experimental Expenses
Kristin Kranich, Senior Manager, Crowe LLP
James Doub, Manager, Crowe LLP
10:30 AM - Break
10:45 PM - Controlled Foreign Corporations (CFCs), Subpart F Income and Global Intangible Low Taxed Income (GILTI)
Overview of U.S. Anti-Deferral Regime: Key Definitions
· Subpart F
· Controlled Foreign Corporation (“CFC”)
· Effect of Voting Agreements on CFC Determination
· U.S. Shareholder
· Implications to U.S. Shareholders of a CFC
Overview of Subpart F Provision
· Categories of Subpart F Income
· Exceptions to Subpart F Income
GILTI: Income of CFC in Excess of 10% Return on Depreciable Assets
Indhira Demorizi, Tax Director, PricewaterhouseCoopers LLP
12:30 PM – Break for Lunch
1:30 PM - Post US Tax Reform Overview
Base erosion anti-abuse tax (BEAT) — Section 59A
Global intangible low-taxed income (“GILTI”) tax
Foreign derived intangible income (“FDII”) tax
Business interest expense limitation — Section 163(j)
Anti-hybrid rules — Section 267A
Participation exemption — Section 245A
Zey Nasser, Executive Director-International Tax Services, Ernst & Young LLP
Kyle Defouw, Manager, Ernst & Young LLP
2:30 PM - Break
2:45 PM - Transfer Pricing
Overview of Transfer Pricing and the Arm’s Length Principle
Overview of Categories of Intercompany Transactions
Transfer Pricing for Tangible Good Transfers
Transfer Pricing for Services Transactions
Transfer Pricing for IP Transactions
Transfer Pricing Documentation and the Compliance Exercise
Tamara A. Levin, Tax Partner, Baker & McKenzie LLP
Tiffany Chang, Tax Associate, Baker & McKenzie LLP
3:45 PM - 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
Elizabeth Lieb, Of Counsel, Baker & McKenzie LLP
Grace Meador, Tax Associate, Baker & McKenzie LLP
5:00 PM - Seminar adjourns for the day
Wednesday, July 24, 2019
8:30 AM - Day Two Registration Opens
9:00 AM - Foreign Earnings & Profits
Introduction & Earnings and profits (“E&P”) generally
Why is E&P important
Computation of E&P and Planning
Michael Palmer, Tax Director, PricewaterhouseCoopers LLP
10:00 AM - Refreshment Break
10:15 AM - Tax Reporting Requirements for Foreign Operations/ New Forms and Changes to Existing Forms and Foreign Tax Credits
Form 5471, Controlled Foreign Corporations
Form 8858, Foreign Disregarded Entities
Form 8865, Controlled Foreign Partnerships
Form 1118, U.S. Foreign Tax Credits
Other common forms
Zey Nasser, Executive Director-International Tax Services, Ernst & Young LLP
12:15 PM - Break for Lunch
1:15 PM - Cross-Border Mergers & Acquisitions
Section 367 – Impact of Tax Reform Act (TCJA)
Outbound transfers under Section 367(a)
Treatment of E&P of foreign entities under Section 367(b)
Outbound transfers of intangibles under Section 367(d)
Other Cross-Border Structuring and Impact of Tax Reform Act
Section 304 and Cash D reorganizations
Section 338(g) election
Inbound liquidations – Section 331 v. Section 332
Stock Ownership Attribution Rules under Section 958
Changes under Tax Reform Act
Implications to M&A transactions
Ben Olivas, Tax Partner, DLA Piper LLP
2:45 PM - Question & Answers
3:00 PM - Seminar Concludes
Conference Location & Sponsor:
Tiffany Chang is an associate in Baker McKenzie's Tax Practice Group in San Francisco. Tiffany assists clients in all stages of tax disputes — from audit and administrative appeals before the IRS to litigation before the United States Tax Court and other federal courts. Tiffany also advises companies on transfer pricing matters, including documenting intercompany transactions and developing pricing policies. She is a member of the State Bar of California and speaks English and Mandarin.
Kyle DeFouw is a manager in Ernst & Young LLP’s International Tax and Transaction Services practice and is based in San Francisco. Kyle has more than 7 years of experience providing tax consulting services for a plethora of inbound and outbound multinational organizations as well as navigating tax compliance and audited financial statements requirements for such organizations. Specifically, Kyle has experience with planning and compliance relative to US taxable income inclusions (e.g., Subpart F and GILTI), FDII deductions, BEAT tax liabilities, US permanent establishments, and the foreign tax credit. He also has experience with buy-side and sell-side tax due diligence efforts, preparation and audits relative to income tax provisions reflected on audited financial statements, and various cross-border restructuring. Prior to joining Ernst & Young LLP, he spent six years within Grant Thornton LLP’s International Tax Services group in Chicago. Kyle is a CPA licensed to practice in both Illinois and California. He is a member of the AICPA and holds a BS in Accounting and a MS in Accounting (tax focus) both from Michigan State University, where he graduated summa cum laude.
Indhira Demorizi has over 10 years of experience providing tax planning and compliance services focusing on U.S. and international tax matters at a flow through and corporate level. She has serviced a wide range of clients in our Asset Management practice including private equity, hedge funds, and venture capital funds, as well as, private and public companies in various industries including technology, retail, life science, and mining. Indhira’s experience in international tax encompasses a wide range of projects including acquisition, post-acquisition, and divestiture structure planning and implementation, IP planning, cash repatriation analyses, U.S. inbound and outbound tax issues and opportunities (Subpart F, Investments in US property, Personal Holding Company Income (PFIC), Effectively Connected Income, Foreign Investment in U.S. Real Estate Property (FIRPTA), U.S. withholding tax, tax treaty analyses, and the U.S. tax compliance with respect to such investments and transactions.
James Doub is a manager in the International Tax Services group at Crowe LLP. He has six years of public accounting and private industry experience. James helps facilitate, supervise and review international tax compliance for several large clients. He assists in many international tax structuring and consulting projects with the aim of global tax minimization. He is a trusted resource within Crowe with respect to tax reform impacts in the area of international taxation.
Kristin Kranich is an senior manager in the International Tax Services group at Crowe LLP. She has 13 years of public accounting experience. She manages international tax services for public and private clients. Kristin specializes in international tax planning and compliance with respect to inbound and outbound investments. She assists companies with navigating the complexities of tax reform and the impact to their business.
Elizabeth Lieb practices in the area of corporate and international tax planning at Baker & McKenzie in Palo Alto, CA. Ms. Lieb’s practice emphasizes a variety of international tax planning matters for multinational corporations, including structuring and implementing international operations, such as intangible property arrangements, and manufacturing and services supply chains. She also advises on subpart F planning, tax treaties, and the tax aspects of multi-jurisdictional post-acquisition integrations and other corporate reorganizations. Prior to joining Baker & McKenzie in 2007, Ms. Lieb worked as a tax associate in the Menlo Park office of Shearman & Sterling LLP and as Attorney Advisor to the Honorable Carleton D. Powell of the United States Tax Court. Ms. Lieb has lectured on Section 956 Investments in United States Property for Bloomberg/BNA CITE, and Income Tax Treaties for Networking Seminars. Ms. Lieb is the co-author of Changes to the “Tax Shelter” Rules After the American Jobs Creation Act of 2004, Practical TaxLawyer (February 2006). Ms. Lieb is a member of the Taxation Section of the American Bar Association and the State Bar of California Taxation Section. She received her LL.M. (Taxation) from New York University School of Law; her J.D. cum Laude from California Western School of Law; and her B.S. (with honors) from the University of Iowa.
Tamara Levin is a partner in Baker McKenzie’s San Francisco/Palo Alto Tax Practice Group. She regularly advises companies, mostly in technology-based industries, on transfer pricing and tax planning matters, including structuring and implementing international operations, cross-border transactions, and post acquisition integrations. Tamara speaks at internal workshops and seminars, as well as external events sponsored by Bloomberg BNA and the Tax Executives Institute. Tamara has extensive experience representing US and foreign multinational companies in a variety of technology-based industries, including software, semiconductor, communications, biotechnology, medical equipment, and online service businesses.
Tamara advises companies on tax aspects of intercompany transactions, including analyzing and documenting transactions and developing pricing policies. Tamara assists clients to comply with complex US and international transfer pricing rules and to anticipate and prepare for global controversies in this area. Tamara also provides tax planning advice for mergers, acquisitions and post-acquisition integrations.
Grace Meador is an associate at Baker & McKenzie’s in the San Francisco office's Tax Practice Group. She is a member of the Taxation Section of the State Bar of California and the American Bar Association. Grace's practice involves all areas of domestic and international taxation, with an emphasis on international tax planning and transactions for multinational corporations. She is a member of the State bar of California and speaks English, Japanese and Spanish.
Zey Nasser is a member of Ernst & Young LLP’s International Tax Services practice and is based in San Francisco. Previously, Zey was a tax associate at Clifford Chance US LLP. Zey has more than 16 years of experience providing tax structuring and planning advice for a wide variety of domestic and multi-national clients. Zey has experience in subpart F and foreign tax credit planning, acquisitions and dispositions, spin-offs and foreign in-bound and outbound transactions. Zey also has experience in hybrid and other cross-border financings and in representing issuers and underwriters in US and Euromarket offerings. She has worked on a wide variety of international financial and business transactions, including investment funds, carried interest and management co-investment arrangements, private equity investments and joint ventures. Zey is a tax attorney licensed to practice in California, New York and Washington, DC. She received an LL.M in taxation, on full scholarship, from Georgetown University Law Center.
Ben Olivas is a partner in the International Tax group at DLA Piper in San Jose, CA. He concentrates his practice in international tax and operational structuring, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, post-acquisition integration, and tax controversy. He has worked extensively with US companies doing business in various parts of the world, as well as foreign companies expanding their US operations. Prior to joining the firm, he spent fifteen years at PricewaterhouseCoopers LLP, including seven years as a partner in the international tax group. As a partner in a Big 4 accounting firm, he dealt with international tax issues from both planning and tax provision perspectives.
Michael Palmer is a director in PricewaterhouseCoopers's International Tax Services group. He serves the greater Bay Area. Michael began his career with PwC in the San Jose office, advising Silicon Valley's largest high-tech companies regarding various tax credits and accelerated deductions. Shortly after starting with PwC, Michael joined PwC's Quantitative Solutions team to assist multinational companies with data intensive tax computations. Michael has over 10 years of experience in international tax, with a focus in international tax compliance, Income Sourcing, Costs and Expense Allocation, U.S. manufacturing / export tax incentives and other various areas applying Internal Revenue Code Section 861. In 2007, Michael moved to the Orange County office to service the growing market in Southern California. While in Orange County, Michael was recognized as PwC's Section 199 manufacturing deduction expert. As such, Michael actively educated Orange County companies in regards to the complexities and nuances of the Section 199 deduction, such as the appropriate treatment of allocable Cost of Sales & expense items. Recently, Michael returned to the Bay Area to focus his time and efforts assisting companies with core international tax issues, specifically foreign E&P and Stock Basis. Michael is a CPA licensed to practice in the State of California. He is a member of the AICPA and holds a BS in Accounting, from Utah Valley University