Introduction to International Corporate Taxation
July 23-24, 2019 - San Francisco, CA

Early Registration $1195 (before June 23th) Regular Registration $1395 ; Please use code GRP for Group Registration (3 or more) Save $200 Off Each Registration. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

The seminar will address recent legislative changes for 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 review of international tax filing forms.

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 CPE/CLE Credits

Tuesday, July 23, 2019

8:30 AM - Registration Opens

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

  • 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

Sergei M. Mytko, Managing Director, Crowe Horwath LLP

10:30 AM - Break

10:45 PM - Controlled Foreign Corporations (CFCs), Subpart F Income and Global Intangible Low Taxed Income (GILTI)

  • 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

Indhira Demorizi, Tax Director, PricewaterhouseCoopers LLP

12:30 PM – Break for Lunch

1:30 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

Zey Nasser, Managing Director, Ernst & Young LLP

2:30 PM - Break

2:45 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

3:45 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

Elizabeth Lieb, Associate, Baker & McKenzie LLP

Ian Siu, Associate, Baker & McKenzie LLP

5:00 PM - Seminar adjourns for the day

Wednesday, July 24, 2019

8:30 AM - Day Two Registration Opens

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

Michael Palmer, Tax Director, 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

Zey Nasser, Managing Director, Ernst & Young LLP

12:15 PM - Break for Lunch

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

Ben Olivas, Partner, DLA Piper LLP

2:45 PM - Question & Answers

3:00 PM - Seminar Concludes

Conference LocationBreak for

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Regus
One Market Place, One Market, Spear Tower, 36th floor,
San Francisco, California, 94105

Hotel Recommendations: Hyatt Regency San Francisco, 5 Embarcadero Center, San Francisco, CA 94111 (415) 788-1234 Rates starting at $297 per night

Participating Speakers

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Indhira Demorizi has over 10 years of experience providing tax planning and compliance services focusing on U.S. and international tax matters at a flow through and corporate level. She has serviced a wide range of clients in our Asset Management practice including private equity, hedge funds, and venture capital funds, as well as, private and public companies in various industries including technology, retail, life science, and mining.  Indhira’s experience in international tax encompasses a wide range of projects including acquisition, post-acquisition, and divestiture structure planning and implementation, IP planning, cash repatriation analyses, U.S. inbound and outbound tax issues and opportunities (Subpart F, Investments in US property, Personal Holding Company Income (PFIC), Effectively Connected Income, Foreign Investment in U.S. Real Estate Property (FIRPTA), U.S. withholding tax, tax treaty analyses, and the U.S. tax compliance with respect to such investments and transactions.

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Elizabeth Lieb practices in the area of corporate and international tax planning at Baker & McKenzie in Palo Alto, CA. Ms. Lieb’s practice emphasizes a variety of international tax planning matters for multinational corporations, including structuring and implementing international operations, such as intangible property arrangements, and manufacturing and services supply chains. She also advises on subpart F planning, tax treaties, and the tax aspects of multi-jurisdictional post-acquisition integrations and other corporate reorganizations. Prior to joining Baker & McKenzie in 2007, Ms. Lieb worked as a tax associate in the Menlo Park office of Shearman & Sterling LLP and as Attorney Advisor to the Honorable Carleton D. Powell of the United States Tax Court. Ms. Lieb has lectured on Section 956 Investments in United States Property for Bloomberg/BNA CITE, and Income Tax Treaties for Networking Seminars.  Ms. Lieb is the co-author of Changes to the “Tax Shelter” Rules After the American Jobs Creation Act of 2004, Practical TaxLawyer (February 2006). Ms. Lieb is a member of the Taxation Section of the American Bar Association and the State Bar of California Taxation Section. She received her LL.M. (Taxation) from New York University School of Law; her J.D. cum Laude from California Western School of Law; and her B.S. (with honors) from the University of Iowa.

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Darren Lo has been providing transfer pricing consulting to various multinational and middle market companies for over 12 years. He has extensive experience in evaluating and comparing transfer pricing strategies, economic modeling, and providing support for planning and compliance with local transfer pricing rules. Darren has a complete understanding of transactions including intangible property migration buy-ins and cost sharing, transfers of tangible and intangible goods, services, royalties, and loans. He has experience with companies in a wide variety of industries including technology (hardware and software), clothing and apparel, manufacturing and distribution, real estate, aerospace, automotive, food processing, and mining.  Prior to joining Moss Adams, Darren spent seven years assisting clients, including several of the top 50 Fortune 500 companies, with transfer pricing that maximizes overall firm profits and optimizes efficient taxation. Prior to that he was a transfer pricing and economic analyst in Australia where his responsibilities included analysis of cross-border transactions, pricing controversy in response to Australian Taxation Office (ATO) information requests and audit position papers, and preparation of “Advance Pricing Agreements” with clients on a bilateral and unilateral basis. Darren is a Chartered Accountant with the Institute of Chartered Accountants in Australia, a member of the American Institute of CPAs (AICPA) and the California Society of Certified Public Accountants.

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Zey Nasser is a member of Ernst & Young LLP’s International Tax Services practice and is based in San Francisco.  Previously, Zey was a tax associate at Clifford Chance US LLP.  Zey has more than 16 years of experience providing tax structuring and planning advice for a wide variety of domestic and multi-national clients. Zey has experience in subpart F and foreign tax credit planning, acquisitions and dispositions, spin-offs and foreign in-bound and outbound transactions.  Zey also has experience in hybrid and other cross-border financings and in representing issuers and underwriters in US and Euromarket offerings.  She has worked on a wide variety of international financial and business transactions, including investment funds, carried interest and management co-investment arrangements, private equity investments and joint ventures.  Zey is a tax attorney licensed to practice in California, New York and Washington, DC.  She received an LL.M in taxation, on full scholarship, from Georgetown University Law Center.

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Ben Olivas is a partner in the International Tax group at DLA Piper in San Jose, CA. He concentrates his practice in international tax and operational structuring, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, post-acquisition integration, and tax controversy. He has worked extensively with US companies doing business in various parts of the world, as well as foreign companies expanding their US operations.  Prior to joining the firm, he spent fifteen years at PricewaterhouseCoopers LLP, including seven years as a partner in the international tax group. As a partner in a Big 4 accounting firm, he dealt with international tax issues from both planning and tax provision perspectives.

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Michael Palmer is a director in PricewaterhouseCoopers's International Tax Services group. He serves the greater Bay Area.  Michael began his career with PwC in the San Jose office, advising Silicon Valley's largest high-tech companies regarding various tax credits and accelerated deductions.  Shortly after starting with PwC, Michael joined PwC's Quantitative Solutions team to assist multinational companies with data intensive tax computations.  Michael has over 10 years of experience in international tax, with a focus in international tax compliance, Income Sourcing, Costs and Expense Allocation, U.S. manufacturing / export tax incentives and other various areas applying Internal Revenue Code Section 861.  In 2007, Michael moved to the Orange County office to service the growing market in Southern California. While in Orange County, Michael was recognized as PwC's Section 199 manufacturing deduction expert.  As such, Michael actively educated Orange County companies in regards to the complexities and nuances of the Section 199 deduction, such as the appropriate treatment of allocable Cost of Sales & expense items.  Recently, Michael returned to the Bay Area to focus his time and efforts assisting companies with core international tax issues, specifically foreign E&P and Stock Basis.  Michael is a CPA licensed to practice in the State of California. He is a member of the AICPA and holds a BS in Accounting, from Utah Valley University