Introduction to International Corporate Taxation
March 21-22, 2019 - New York, NY

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 CPE/CLE Credits

Thursday, March 21, 2019

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

Eric Gabbai, Senior Manager, Grant Thornton LLP

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

Gabe Taubenfeld, Senior Manager, Ernst & Young LLP

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

Gabe Taubenfeld, Senior Manager, Ernst & Young LLP

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

3:15 PM – Refreshment Break

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

Justin Donatello, Senior Manager, KPMG LLP

5:15 PM - Seminar adjourns for the day

Friday, March 22, 2019

8:30 AM - Registration Opens

9:45 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

Michael Turgeon, Partner, PricewaterhouseCoopers LLP

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

  • Form 8833, Treaty Based Return Positions

Rivi Biton, Consultant International Tax

11:00 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

Sashka Koleva, Senior Manager, KPMG LLP

12:15 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

Matvey Kats & Greg Dziura, Deloitte Tax LLP

2:30 PM – Questions & Answers

2:45 PM - Seminar Concludes


Early Registration $1195 (before Feb. 22nd) Regular Registration $1395 - Group Registration 3 or more registrants use code GRP save $200 off each registrant - Please submit each registrant separately. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

Regus, 1501 Broadway, 12th Floor
New York, New York, 10036-5601
PH:
646 571 2000

Speaker Biographies

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Rivi Biton is a Certified Public Accountant and International Tax Consultant in New York.  Rivi specializes in International Tax Quantitative Services in New York. Prior to starting her own business, she was a senior manager in Ernst & Young LLP’s International Tax Services for over 10 years.  Rivi’s experience also includes Federal and Individual Taxation. Ms. Biton is also an adjunct accounting professor and teaches various classes including corporate taxation and Auditing.  Rivi helps her clients with their U.S. requirement for their foreign investments whether they be corporations, partnerships, or disregarded entities. She executes the filing requirements for cross border transactions and M&A deals for her clients mostly in the media and entertainment or financial industries. She holds an Accounting and Finance B.S., as well as, a J.D. She is licensed attorney in NY and is an admitted in the Second Circuit Southern District of New York. 

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Justin Donatello is a Senior Manager in the Tax Controversy Services practice at KPMG LLP in New York, which represents firm clients at all levels of controversy before the IRS. The practice represents clients at the examination and appeals level, using both traditional resolution methods and various alternative dispute resolution techniques such as mediation. Justin’s practice covers all areas of tax controversy representation before the IRS, from pre-dispute (voluntary disclosures and Pre-Filing Agreements), through the examination, Appeals, and post-Appeals dispute resolution phases. Justin’s clients include multinational corporations from a broad range of industries, including major financial institutions. Justin earned his B.A., magna cum laude, from Quinnipiac University, his J.D., cum laude, from Western New England College School of Law, and his LL.M. in Taxation from New York University School of Law.

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Eric Gabbai is a Senior Manager with Grant Thornton LLP in Atlanta, GA.  He has over 10 years of public accounting experience serving manufacturing, retail, healthcare, and technology clients throughout the southeast region.  Some of Eric’s specific experience includes: Extensive experience serving US based multinationals with outbound operations, foreign owned inbound US corporations, and closely held businesses engaged in domestic and foreign activities; Cross border tax restructurings; Tax-efficient cash repatriation planning; Foreign tax credit planning; Preparation and review of tax compliance and reporting matters including transactional reporting; Assisting and review of income tax accounting for foreign operations as part of corporate tax provision calculations. Eric is a Certified Public Accountant in Georgia. Eric graduated cum laude with a BS, in Accounting, and a Master’s Degree, in Accounting, with a focus in Taxation, from The University of Georgia’s J.M. Tull School of Accounting

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Sashka Koleva is a senior manager in KPMG’s Tax Controversy Services practice. Sashka advises clients on all aspects of their federal tax controversies, from examination through post-Appeals mediation, with an emphasis on domestic and international tax issues in the financial services industry. Prior to joining KPMG, Sashka was an attorney with the IRS Office of Chief Counsel, Large Business & International, advising IRS exam teams and the Office of Appeals on both domestic and international tax issues arising from the audits of large financial institutions, hedge funds, and insurance companies, such as investment tax credits, taxation of financial instruments, deferral and foreign tax credit planning, U.S. tax treaty issues, and Chapter 3 withholding. During her tenure with the IRS Office of Chief Counsel, she served as counsel to the Issue Management Team on Foreign Tax Credit Generators and was a member of the Steering Committee of the Foreign Tax Credit International Practice Network. She also served as U.S. Counsel to the Joint International Tax Shelter Information Centre (“JITSIC”). Sashka is admitted to practice in New York. She earned her LL.M. in taxation from New York University School of Law and her J.D. from The University of Texas at Austin.