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

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

Conference Location & Sponsor:

Polsinelli LLP
1000 Louisiana Street, Suite 6400, Houston, TX 77002

 

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

Tuesday, November 13, 2018

8:30 AM - Registration and Continental Breakfast

9:00 AM – Overview, Source of Income, Allocation and Apportionment of Expenses

  • Understanding worldwide vs. territorial tax systems

  • Residence vs. activity based tax jurisdiction

  • Taxation of foreign income of U.S. corporations

  • 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

Joseph David, Senior Manager, KPMG LLP, Houston, TX

10:30 AM - Refreshment Break

10:45 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

  • GILTI:  Income of CFC in Excess of 10% Return on Depreciable Assets

  • Previously Taxed Income

  • PFICS

John Woodruff, Shareholder, Polsinelli LLP, Houston, TX

12:30 PM – Luncheon

1:00 PM - 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 Refreshment Break, then CFCs continues

Sarah Busker, Executive Director, Ernst & Young LLP, Houston, TX

2:00 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

John Woodruff, Shareholder, Polsinelli LLP, Houston, TX

3:00 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

Lillie Sullivan, Manager, KPMG LLP, Houston, TX

4:00 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

Scott A. Sicinski, Senior Manager, KPMG LLP, Houston, TX

5:15 PM - Seminar adjourns for the day

Wednesday, November 14, 2018

8:30 AM - Registration

9:00 AM - Tax Reform’s Impact on International Business Transactions

  • Overview of old/new international framework

  • Mandatory Repatriation (Section 965)

  • Global Intangible Low Tax Income (“GILTI”)

  • Foreign Derived Intangible Income (“FDII”)

  • Base Erosion Anti-Abuse Tax (“BEAT”)

Mia L Bertagnolli, Senior Manager, Ernst & Young LLP, Houston, TX
Mike Crafton, Senior Manager, Ernst & Young LLP, Houston, TX

11:00 AM - Refreshment Break

11:15 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

Sarah Busker, Executive Director, Ernst & Young LLP, Houston, TX
Robin Ching, Senior Manager, Ernst & Young LLP, Houston, TX

12:30 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

Nathan Galvin, Manager, KPMG LLP, Houston, TX
Grant Gooding, Senior Manager, KPMG LLP, Houston, TX

2:45 PM - Question & Answers

3:00 PM - Seminar Concludes

Conference Sponsored by & Location:

Polsinelli LLP
1000 Louisiana Street, Suite 6400
Houston, TX 77002

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Hotel Recommendation: Hyatt Regency Houston, 1200 Louisiana St, Houston, TX 77002. Phone: (713) 654-1234

Conference Chairman:

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John T. Woodruff is an experience tax attorney at Polsinelli LLP in Houston, TX. John strives to provide practical and efficient solutions to complex tax matters. John provides advice on all aspects of international tax, transfer pricing, and tax issues related to cross-border mergers, acquisitions, and restructurings. He regularly counsels 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 ways that best protect each client's interests. John also represents multi-national clients operating in a broad range of industries, with a particular focus on energy companies. John is admitted to practice in Texas and Virginia. John received his LL.M. from Georgetown University Law Center, Tax and his J.D. from University of Tulsa College of Law, Phi Delta Phi.  

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Mia Bertagnolli is a Senior Manager in Ernst & Young LLP’s International Tax Services practice and currently serves as a member of Ernst & Young’s Americas Tax Advisory Forum. Her international tax consulting experience includes cross-border supply chain planning and IP migration, internal and external restructurings and reorganizations, and cross-border financing and investment structures. She has extensive experience advising clients on international tax issues pertaining to technology, engineering and construction, manufacturing and all facets of the oil and gas supply chain, including foreign tax credits, expense apportionment, tax accounting considerations and the impact of US tax reform. Mia has a BBA with a concentration in Finance and Accounting and Masters in Accounting and Taxation from the University of Houston. She is a licensed Texas certified public accountant.

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Sarah Busker is an Executive Director in Ernst & Young’s Houston office.  Sarah has over 10 years of experience in international tax compliance and reporting.  Areas of expertise include: tax reporting of foreign subsidiaries, US tax reporting of foreign corporations, foreign bank account reporting, foreign tax credit reporting and Section 987.  Other areas of experience include real estate partnerships and federal tax compliance.  Sarah joined Ernst & Young in 2002 upon her completion of the Professional Program in Accounting at Texas A&M University.  Sarah holds a BA in Business Administration and a MS in Taxation.  She is a Texas CPA and a member of the AICPA.

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Rolin Ching is a senior manager that has more than 17 years of professional experience at both EY and another Big 4 accounting firm.  She has a specialization in International Compliance and has provided tax services to both public and privately held Oil & Gas, Drilling, Real Estate, Manufacturing, Food & Beverage, and Aerospace companies in the United States and around the world. Rolin has experience working in International Tax Compliance and has advised clients on issues including Subpart F income, Earnings and Profits, creditability of foreign taxes, sourcing of income and application of 861 expense apportionment, US taxation of foreign corporations with US operations, and withholding tax issues. She has worked extensively in business tax compliance, specializing in international tax.  She has been involved with the review and preparation of international compliance forms, which includes Forms 1118, 5471, 8858, 8865, 5472, 1120-F, 1042, and 926.  

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Mike Crafton is a Senior Manager in Ernst & Young LLP’s International Tax Services practice, based in Houston. Mike has over 11 years of experience in inbound and outbound international tax consulting with various professional services firms.  Areas of experience include permanent establishment/US trade or business issues, IP partnership planning, out from under planning and debt financing among other inbound and outbound planning. Mike currently primarily services the energy and petrochemical industry but has extensive previous industry experience in pharmaceuticals, consumer products, transportation and technology industries.  Mike has a BA from the University of San Diego in Political Science and History and a JD from Seton Hall University School of Law.  He is licensed in the states of New York and New Jersey.

Joseph Z. David is a Senior Manager with KPMG’s International Corporate Services practice in Houston.  His work includes both outbound and inbound tax consulting for U.S. and foreign multinationals.  He has served clients in various industries including oil and gas, industrial products, services, high-tech, pharmaceuticals, apparel and shipping.  Joe earned his BA from Williams College and his JD from the University of Washington School of Law.

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Nathan Galvan is a Manager in the Houston office of the Deloitte Tax LLP International Tax Practice. He has broad based experience in cross-border transactions, U.S. inbound investment structuring, foreign cash repatriation, and U.S. federal income tax compliance. His clients include large publicly traded and privately held companies across a range of industries, including: oil and gas, restaurant and entertainment, manufacturing, technology, and private equity. Nathan received a BBA in accounting from Texas State University and a Masters in Accounting from Southern Methodist University.

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Grant Gooding is a Tax Senior Manager at Deloitte Tax LLP in the international tax service line located in Houston, Texas.  Grant serves multinational corporations in a variety of industries including offshore contract drilling, shipping, agriculture commodity growers and food distribution, and oil field services. Grant has over 12 years of experience advising clients in areas of U.S. taxation, including M&A, tax efficient financing, foreign tax credit planning (including expense apportionment and overall foreign loss planning), initial structuring for new country investments, and repatriation strategies. Grant also has experience advising clients in certain aspects of inbound international taxation including FIRPTA, earnings stripping, internal restructurings and disposition planning.

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Scott Sicinski is currently a Houston based Senior Manager in KPMG’s International Tax practice. He has over 12 years of experience practicing in a wide range of tax areas. He began his career with Ernst & Young’s International Tax group primarily serving energy focused inbound and outbound clients, and then rotated to the firm’s M&A tax practice as an international tax specialist. He joined Hess Corporation in 2013 as tax counsel, acting as point person for a wide range of tax planning matters, including but not limited to (1) the company’s US and international business development initiatives, (2) US exploration and production for both the onshore and offshore asset teams, (3) Mexico exploration, (4) Canada exploration, and (5) US Crude/Gas marketing. He has both a law degree and engineering degree from Texas Tech University, and is licensed by the State Bar of Texas.

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Lillie Sullivan is a Manager in KPMG’s national Transfer Pricing Dispute Resolution Services practice. Lillie represents multinational enterprises in transfer pricing and international tax controversy matters. Her work in transfer pricing dispute resolution largely consists of preparing advanced pricing agreement and competent authority requests and submissions. She also prepares transfer pricing documentation, drafts intercompany agreements, and performs research and provide assistance for transfer pricing advising and international tax planning and controversy matters. She prepares and develops Advance Pricing Agreements and Competent Authority settlements between multinational corporations, the IRS and foreign governments, including China, Canada, India, Spain, Switzerland, the United Kingdom, Japan, and the Netherlands. She analyzes U.S. income tax treaties to provide clients with double tax relief on the following non- transfer pricing issues: permanent establishment, income sourcing and characterization, and shipping and transportation income. She also assists clients with navigating IRS Examination and Appeals including responding to Information Document Requests and preparing protest letters. She earned her BA from Southwestern University, her JD from University of Texas and is a licensed attorney in the State of Texas.