Introduction to International Corporate Taxation
November 6-7, 2019 - Chicago, IL

Early Registration is $1195 until October 7th. Regular Registration is $1395. Groups of 3 or ore use code GRP for a $200 savings. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

The seminar will teach the fundamentals of international taxation and focus on basic international corporate tax planning and include discussions on the Tax Cuts and Jobs Act ("TCJA") and how it is changing the global tax landscape.  It will also include what tax payers should be thinking about while planning for the future, as well as perspectives on the TCJA.

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 13.5 CPE/CLE Credits

Sponsored By

Grant Thornton Chicago
171 N. Clark Street, Chicago, IL 60601

Wednesday, November 6, 2019

8:00 AM - Registration

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

  • 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

Edward Weaver, Partner, Grant Thornton LLP, Chicago, IL

10:30 AM - Refreshment Break

10:45 AM - Controlled Foreign Corporations (CFCs) and Subpart F Income

  • 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

Jake Koch, Tax Manager, Grant Thornton LLP, Chicago, IL

12:15 PM – Luncheon

1:15 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

Robert J. Misey, Jr., Partner, Reinhart Boerner Van Deuren, Milwaukee, WI & Chicago, IL

2:15 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

Eileen Leyhane, Tax Manager, Grant Thornton LLP, Chicago, IL

3:30 PM – Break

3:45 PM - Foreign Earnings and Profits

  • Introduction & Earnings and profits (“E&P”) generally

  • Why is E&P important

  • Computation of E&P and Planning

Caitlin Reese, Manager, PricewaterhouseCoopers LLP, Chicago, IL

5:00 PM - Seminar adjourns for the day

Thursday, November 7, 2019

8:00 AM - Registration

9:00 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

Charlotte Hanselmann, Tax Senior, Grant Thornton LLP, Chicago, IL

10:30 AM – Break

10:45 AM – 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”

Brandon Joseph, Senior Manager, Grant Thornton LLP, Chicago, IL

12:15 PM - Luncheon

1:00 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

Maggie Bafia, Tax Manager, Grant Thornton LLP, Chicago, IL

2:30 PM - Question & Answers

2:45 PM - Seminar Concludes

Conference Location: 

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Grant Thornton,
171 N. Clark Street, Suite 200,
Chicago, IL. 60601

Hotel Recommendations:  Cambria Hotel Chicago Loop 32 W. Randolph St., Chicago, IL

Speaker Biographies

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Maggie Bafia is a Manager in Grant Thornton’s Chicago office specializing in mergers and acquisitions consulting. She has worked closely on numerous transactions with complex tax issues arising from transactions and other M&A activities including variety of transactions to assist clients with buy and sell side due diligence, tax structuring and modeling, merger integration, and tax attributes analysis. Maggie has been involved in a wide variety of transactions across numerous industries, ranging from $2M acquisitions of privately-held businesses to billion dollar transactions involving multi-nationals and public companies. She has extensive experience with cross-border due diligence and structuring engagements, working directly with Grant Thornton member firms in various countries, helping clients efficiently and effectively execute on multi-national transactions.  Maggie is a Certified Public Accountant in the state of Illinois. She earned a Bachelors in Business Administration in Accounting and Finance from Loyola University Chicago.

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 Charlotte Hanselmann is a Senior Associate of Grant Thornton’s International Tax practice and is based in Chicago. At Grant Thornton, Charlotte handles a broad range of federal and international tax matters including corporate tax returns, international filings, subpart F income considerations, foreign currency transactions, foreign tax credits, application of U.S. income tax treaties and U.S. inbound tax issues. Charlotte is a Certified Public Accountant in the State of Illinois and is a member of the American Institute of Certified Public Accountants. Charlotte received a Bachelor of Business Administration in Accounting (Magna Cum Laude) and a Bachelor of Business Administration (Magna Cum Laude) from Loyola University Chicago.

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Brandon Joseph is a Senior Manager in Grant Thornton’s International Tax group in Chicago. He has ten years of public accounting experience serving multinational clientele.  Brandon has extensive experience advising U.S. multinational companies on cross-border planning and tax compliance matters; including foreign tax credit planning, cash repatriation/deferral planning, international structuring, IRS controversy, transaction due diligence, and fulfilling IRS/FinCEN foreign reporting requirements. Brandon maintains a strong relationship with Grant Thornton's network of international firms to serve clients global tax compliance and planning needs. Brandon spends the majority of his time serving clients in the manufacturing, distribution, and service industries. He is an Illinois Licensed CPA and is a member of American Institute of Certified Public Accountants (AICPA).

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 Jake Koch is a manager in Grant Thornton’s international tax practice. He has a broad knowledge of the U.S. tax implications which affect the business operations of U.S. and foreign multinational companies with operations in the U.S. and abroad, including: M&A, check-the-box planning, compliance and reporting, holding company structuring, foreign tax credit planning, earnings and profits and tax basis studies, and IC-DISC export incentives. Jake is a licensed attorney and received his J.D. from University of Saint Thomas.

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Eileen Leyhane is a Manager in Grant Thornton’s International Tax practice with Grant Thornton’s Chicago office. Eileen has more than six years of experience working on international and domestic tax issues. Prior to joining Grant Thornton, Eileen worked at the Tribune Company in their tax department. At Grant Thornton, Eileen handles a broad range of federal and international tax matters including corporate tax returns, international filings, subpart F income considerations, foreign currency transactions, international tax treaties and tax accounting. Eileen received a Bachelor of Business Administration in Accounting (Summa Cum Laude) and a Bachelor of Business Administration in Finance (Summa Cum Laude) from Loyola University Chicago.

Robert J. Misey, Jr.

Robert J. Misey, Jr. is a shareholder in Reinhart’s Tax and Corporate Law Practices as well as chair of the firm’s International Practice. He serves with a wide range of clients involved in an array of industries such as manufacturing, distribution, sport, and entertainment with international taxation and tax controversy matters. Licensed in California, Wisconsin, Kentucky and Washington, D.C., Rob is also a member of the International Fiscal Association and Chair of the Tax Committee of International Section of the American Bar Association. As a seasoned attorney, Rob offers clients unparalleled legal representation. He also regularly shares his expertise and experience on international taxation with business with national and international professional audiences. He also teaches international taxation at the University of Wisconsin and University of Alabama law schools. He has an LL.M., with high distinction from Georgetown University Law Center; earned his J.D. from Vanderbilt University Law School; his M.B.A. from Vanderbilt University and his B.A. form the University of Kentucky

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Ed Weaver is a senior manager at Grant Thornton in our international tax practice. Ed has over twelve years of experience advising multinational clients on international and domestic tax issues. Ed handles a broad range of international tax matters including foreign tax credits, subpart F income, mergers and acquisitions, foreign currency transactions, tax treaties and tax accounting. Prior to joining Grant Thornton, Ed worked at Deloitte Tax LLP and Northern Trust Corporation. Ed is a frequent speaker on various tax topics and an adjunct professor at John Marshall Law School in Chicago. Ed provides services to a variety of clients, including consumer and industrial products, financial services, and technology companies. Ed received his J.D. and L.L.M. (Taxation) at Loyola University Chicago. He received his Bachelor in Science in Accounting, at University of Illinois at Chicago. Ed is certified public accountant and licensed attorney in Illinois. Ed is a member of the American Institute of Certified Public Accountants and the Chicago Bar Association.