Introduction to International Corporate Taxation
July 31- August 1, 2018 - Chicago, IL

Regular Registration $1395 - Group Discount(Register 3 or more for $995 each use code GRP). 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 14.5 CPE/CLE Credits

Sponsored By

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

Tuesday, July 31, 2018

8:30 AM - Registration

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

  • Understanding worldwide vs. territorial tax systems
  • Residence vs. activity based tax jurisdiction
  • Taxation of foreign income of U.S. corporations
  • U.S. income and sourcing rules
  • Allocating Deductions
  • Special Corporate Deductions
  • Permanent establishment principles and double taxation
  • Claiming a deduction or credit for foreign income taxes
  • Anti-Deferral:  Subpart F and PFIC
  • Special Deductions for Corporations
    • Deduction for Dividends Received from Foreign Corporations
    • Deduction for Foreign Branch Income
    • Deduction for Part of Subpart F Income

Edward Weaver, Senior Manager, Grant Thornton LLP, Chicago, IL

10:00 AM - Refreshment Break

10:15 AM - Source of Income & Allocation and Apportionment of Deductions

  • Source Rules for Types of Income
  • Income from Single and Mixed Sources
  • Establishing Foreign Title Passage
  • The Basic Rules of Allocation and Apportionment
  • Asset Apportionment of Interest Expense
  • The Apportionment of R&E Expenses
  • Tax Planning in Expense Apportionment

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

12:15 PM – Luncheon

1:00 PM - Controlled Foreign Corporations (CFCs), Subpart F Income and Passive Foreign Investment Companies (PFICs)

  • Current Taxation of Subpart F Inclusions
  • 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
  • GILTI:  Income of CFC in Excess of 10% Return on Depreciable Assets
  • Previously Taxed Income
  • PFICS

Samuel Pollack, Associate, Baker & McKenzie LLP, Chicago, IL

3:00 PM – Refreshment Break

3:15 PM - The Foreign Tax Credit

  • Key concepts of the foreign tax credit
  • Taxes available for the credit
  • § 901 direct credits
  • § 960 indirect (deemed paid) credits
  • Foreign tax credit limitation formula
  • Applying the foreign tax credit limitation formula for passive and general baskets
  • § 905 and Redeterminations

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

4:00 PM - 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

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

 5:00 PM - Seminar adjourns for the day

Wednesday, August 1, 2018

8:00 AM - Registration

8:30 AM - Earnings and Profits and Net Subpart F Income

  • U.S. Tax Concepts Used for Subpart F and E&P
  • Earnings and profits (“E&P”) generally
  • Common E&P adjustments
  • The steps in preparing an E&P study
  • Preparing a computation of E&P post-1986
  • Practical issues in calculating E&P

Kathy McDonald, Executive Director, Ernst & Young LLP, Chicago, IL

9:15 AM - PFIC, post-2017

  • What Is a PFIC, and Why Do You Care?
  • Impact:  Lost Deductions, No Foreign Tax Credit
  • QEF Inclusions
  • Tax and Interest Regime

9:30 AM - Refreshment Break

9:45 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
  • Form 8833, Treaty Based Return Positions

Kathy McDonald, Executive Director, Ernst & Young LLP, Chicago, IL

11:15 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

12:30 PM - Luncheon

1:00 PM - 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

2:30 PM - Question & Answers

2:45 PM - Seminar Concludes

Conference Location: 

Grant-Thornton.jpg

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

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

Edward Weaver.jpg

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.