Introduction to U.S. International Tax

May 8 - 9, 2017 in New York, NY

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, May 8, 2017

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
  • Permanent establishment principles and double taxation
  • Claiming a deduction or credit for foreign income taxes

William H. Green, Director, Perelson Weiner LLP, New York, NY

10:15 AM - Refreshment Break

10:30 AM - Source of Income, Allocation and Expense Apportionment

  • Residence For Taxation
  • Income From Single and Mixed Sources
  • Establishing Foreign Title Passage
  • Tax Planning to Create or Increase Foreign Source Income
  • The Basic Rules of Allocation and Apportionment
  • The Apportionment of R&E Expenses
  • Asset Apportionment of Interest Expense
  • Tax Planning in Expense Apportionment

Brandon Svetcov, Senior Manager, Ernst & Young LLP, New York, NY

12:00 AM – Networking Luncheon

12:30 PM - Controlled Foreign Corporations (CFCs), Passive Foreign Investment Companies (PFICs) and Subpart F Income

  • 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

2:15 PM – Refreshment Break

2:30 PM - The Foreign Tax Credit

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

Joseph Malca, Associate, Baker & McKenzie LLP, New York, NY

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

Justen Ghwee, Economic & Valuation Services, KPMG LLP, New York, NY

5:15 PM - Seminar adjourns for the day

    Tuesday, May 9, 2017

    8:30 AM - Continental Breakfast

    9:00 AM - 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

    Chad Schneider, Senior Manager, PricewaterhouseCoopers LLP, New York, NY

    10:00 AM - Refreshment Break

    10:15 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

    William H. Green, Director, Perelson Weiner LLP, New York, NY

    11:45 AM - Luncheon

    12:30 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

    1:45 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

    Sarah Kaiser, Manager, Deloitte Tax LLP, New York, NY
    Matt Auerbach, Senior Manager, Deloitte Tax LLP, New York. NY

    3:15 PM Seminar Concludes

    Conference Location

    Networking Seminars Conference Room c/o Regus
    1501 Broadway (between 43rd & 44th Streets), 12th Floor
    New York, NY 10036
    Phone: 1 646 571 2000

    Hotel accommodations will be recommended during registration - Times Square Location.

    Justen Ghwee is a Senior Manager in KPMG’s Economic and Valuation Services practice.  At KPMG, Justen works in transfer-pricing related issues, including documentation and planning studies and controversy work, and economic services.  Justen has completed transfer pricing studies to determine proper arm’s-length compensation for tangible goods, intangible, and services encompassing multinationals and financial institutions.  Justen has performed economic analysis establishing the arm’s-length range of (i) interest rate and price for financial instruments such as intercompany loans, hybrids and leases, (ii) maximum supportable debt level, and (iii) price for financial services such as loan guarantee service and loan commitment fees.  Justen has participated as project team member on Advance Pricing Agreement, audit defense and tax controversy engagements for companies seeking assurance in matters pertaining to their transfer pricing arrangements.  Justen received his Ph.D. in Economics from the University of Texas at Austin and his B. Commerce in Finance from Hitotsubashi University (Japan).

    William H. Green is a Director, Quality Control, Tax Department at Perelson Weiner LLP, with extensive experience in Federal (domestic and international) tax compliance and planning, He is responsible for maintaining the highest standards of performance for the firm's tax practice. In his over 35 years in the profession, he has managed tax practices for both public companies and national accounting firms. Bill is a consultant and advisor with foreign-based multinationals and individuals.  Bill is well qualified as an educator and manager having founded and directed development and production of continuing education course for Federal tax practitioners and administrators, including certified public accountants, lawyers and IRS agents. In addition his role at an International Public Accounting firm, he managed the US and cross border tax planning and worked extensively in obtaining IRS rulings and handling transfer pricing audits. Having worked on the client side, Bill directed the international tax function at a public multinational corporations, one involved in the global production and sale of branded food products and the other at a global computer and military and farm equipment manufacturing and distribution business, where he was responsible for overseeing tax provision calculation and IRS compliance.  Bill graduated with a BA from Trinity College, and received his JD from Suffolk University Law School. He is a member of the New York State Bar, the U.S. SDNY and Tax Court; he is an ABA Fellow and member of the Tax Section and a NYSBA Fellow and Tax Section member. He also is a member of the International Fiscal Association.

    Sarah Kaiser is a Manager in the New York office of Deloitte’s International Tax Practice.  Her experience includes design, development, and implementation of cross-border reorganizations in both outbound and inbound contexts.  Sarah has successfully managed numerous complex business restructuring projects including post-acquisition integration and supply chain optimization.  Sarah received her BSBA in Finance and BA in Psychology from the University of Arizona and her JD from The Ohio State University Moritz College of Law.

    Brandon Svetcov is a senior manager in the International Tax Services group with Ernst & Young LLP in New York. Brandon has experience advising multinational clients on US tax aspects of cross-border restructuring transactions, mergers, acquisitions, dispositions and financing arrangements. Additionally, Brandon has experience in tax-efficient cash repatriation planning, income tax treaty analysis and post-acquisition integration planning. Brandon also has experience in advising non-US clients on US taxation related to their US operations, including effectively connected income analysis and US withholding tax matters. Brandon’s experience includes working directly with non-US tax professionals, financial advisors, legal counsel, and other advisors in connection with implementation of complex multinational transactions. Brandon earned a Bachelor of Science degree in business administration from Carnegie Mellon University with a minor in Mechanical Engineering. He earned a Juris Doctor degree from the Benjamin Cardozo School of Law and an LL.M. in tax law from Northwestern University. Brandon is admitted to the New York State Bar as an attorney.