Introduction to International Corporate Taxation
November 13-14, 2018 - Houston, TX

Early Registration $1195 (before October 14th) Regular Registration $1395 - Please call 877-500-1510 for Group Registration (3 or more use code GRP save $200 off each registrant). 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

Conference Location & Sponsor:

Polsinelli LLP
1000 Louisiana Street, Suite 6400, Houston, TX 77002
Phone: 713.374.1600

 

Conference Chairman: John Woodruff, Shareholder, Polsinelli LLP, Houston

Tuesday, November 13, 2018

8:30 AM - Registration and Continental Breakfast

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

    • Deduction for Dividends Received from Foreign Corporations

    • Deduction for Foreign Branch Income

    • Deduction for Part of Subpart F Income

  • Permanent establishment principles and double taxation

  • Claiming a deduction or credit for foreign income taxes

  • Anti-Deferral:  Subpart F and PFIC

10:00 AM - Refreshment Break

10:15 AM - Source of Income

  • Source Rules for Types of Income

  • Income from Single and Mixed Sources

  • Establishing Foreign Title Passage

10:45 AM - Allocation and Apportionment of Deductions

  • The Basic Rules of Allocation and Apportionment

  • Asset Apportionment of Interest Expense

  • The Apportionment of R&E Expenses

  • Tax Planning in Expense Apportionment

12:15 PM – Luncheon

1:15 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

2:30 PM – Refreshment Break, then CFCs continues

3:30 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

4:15 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

5:15 PM - Seminar adjourns for the day

Wednesday, November 14, 2018

8:30 AM - Registration

9:00 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

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

  • Form 8833, Treaty Based Return Positions

11:30 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

12:45 PM - Luncheon

1:15 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

2:45 PM - Question & Answers

3:00 PM - Seminar Concludes

Conference Sponsored by & Location:

Polsinelli LLP
1000 Louisiana Street, Suite 6400, Houston, TX 77002
Phone: 713.374.1600

Conference Chairman:

woodruff_john.jpg

For each engagement, John Woodruff’s goal is to provide strategic, practical, and efficient recommendations for our clients’ complex tax matters. John counsels clients on all aspects of international tax, transfer pricing, and tax issues related to cross-border mergers, acquisitions, and restructurings. He regularly partners with clients on issues related to the U.S. foreign tax credit, subpart F, U.S. trade or business/permanent establishment determinations, treaty-based positions, transfer pricing strategies, and strategic tax-related planning for international investments and financings. 

Drawing on his many years of experience in private practice and in major accounting firms, John structures acquisitions, dispositions, public offerings, reorganizations, restructurings, repatriations, and insolvency transactions in a manner that best protects each client's interests. 

John also represents multi-national clients operating in a broad range of industries