Introduction to U.S. International Tax

June 5 - 6, 2017 - San Francisco, CA

Early Registration: $1095 (before May 6th) Regular Registration: $1295 Groups of 2 or more Save $200 off each registrant

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 prerequisites for this group live seminar. This basic level seminar will explain the various aspects of taxation for U.S. multinational corporations. Field of Study: Taxes  

Earn up to 15 CPE/CLE Credits

Monday, June 5, 2017

8:00 AM - Registration and Continental Breakfast

8:45 AM – Overview of U.S. International Taxation Including Tax Reform

  • 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
  • Overview of President Trump's Business Tax Proposals

Zey Nasser, ITS Senior Manager, Ernst & Young LLP

10:15 AM - Refreshment Break

10:30 AM - The Sourcing of Income including the Allocation and Apportionment of Expenses

  • 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

Aaron Ashcraft, ITS Senior Manager, Ernst & Young LLP

12:00 AM – Networking Luncheon

12:45 PM - Controlled Foreign Corporations (CFCs) and Subpart F Income including Passive Foreign Investment Companies (PFICs)

  • 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

Sam Phaup, ITS Senior Manager, Ernst & Young LLP

2:15 PM – Refreshment Break

2:30 PM - Understanding Foreign Tax Credits including Direct and Indirect Credits

  • 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

Hansen Wong, ITS Senior Manager, Ernst & Young LLP

4:00 PM - The Importance of 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

5:00 PM - Seminar adjourns for the day

Tuesday, June 6, 2017

8:00 AM - Continental Breakfast

8:45 AM - Overview of Transfer Pricing Principles and Methods

  • 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

Romita Mukherjee, ITS Transfer Pricing Manager, Ernst & Young LLP

9:45 AM - Refreshment Break

10:00 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
  • TDF 90-22.1, Foreign Bank Account Reporting

11:30 AM – Income Tax Treaties and Permanent Establishments (PEs)

  • 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
Ian Siu, Associate, Baker & McKenzie LLP

12:45 PM - Luncheon

1:30 PM - Introduction to Cross-Border Mergers & Acquisitions

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

Chris Kotarba, Senior Associate, DLA Piper LLP
Mumi Hemrajani, Senior Associate, DLA Piper LLP

3:00 PM Seminar Concludes

Conference Location

Networking Seminar Conference Room c/o Regus
One Market, Spear Tower, 36th floor,
San Francisco, California, 94105