Hot Issues in U.S. International Taxation

Cover Hot Issues.jpg
Cover Hot Issues.jpg

Hot Issues in U.S. International Taxation

Add To Cart

Hot Issues in U.S. International Taxation

Expense Apportionment Practice Update

·         How expense apportionment affects credits foreign taxes and deduction of U.S. expenses

·         Selecting the best apportionment method - gross-to-gross v. factual apportionment

·         Understanding the rules for interest apportionment – effect of exchange rates on foreign asset bases

·         Strategies for minimizing the apportionment of research, state tax and S,G&A expenses to foreign source income

·         International Tax Reform Proposals

Jason Connery, Principal, KPMG LLP

Foreign Tax Credit Update

·         Obtaining foreign tax credit benefits for foreign withholding taxes – what constitutes a creditable income tax

·         Applying the gross-up formula for foreign taxes

·         Computing the separate foreign tax credit basket limitations - separate limitation loss recapture

·         Applying the related party look-through rules for dividend and interest payments between related CFCs and 10/50 entities

·         How FTC limitations increase the US tax on dividends under Subpart F and Sec. 956

·         Impact of Proposed International Tax Reform

Kevin Cunningham, Managing Director, KPMG LLP

Controlled Foreign Corporations & Subpart F Income Update

·         Identifying CFCs and “U.S. Shareholders”

·         Definition of U.S. shareholder - vote or value ownership

·         Understanding the regulations involving Subpart F FPHC income

·         Working with the branch rules for foreign sales and manufacturing activities

·         Exceptions and limitations on application of the Subpart F rules

·         Avoiding investments in U.S. property by first or lower-tier CFCs

·         Impact of International Tax Reform

Matthew Jenner, Tax Associate, Baker & McKenzie LLP
Keith Hagan, Tax Associate, Baker & McKenzie LLP

Transfer Pricing Developments & BEPS Update

·         Impact of IRS administrative changes on transfer pricing, APAs and Competent Authority cases

·         Developments in cost-sharing, intellectual property and regulatory developments

·         Update on BEPS and transfer pricing

·         Proposed country by country reporting regulations, changes to Section 482 aggregation rules and the treatment to outbound transfer under sections 367 and 721

Thomas A. Vidano, Executive Director, Transfer Pricing Controversy, Ernst & Young LLP

Final Regulations under Section 987

The final regulations outline how owners of a qualified business unit (QBU) subject to Section 987 must determine the QBU’s taxable income or loss, as well as the timing, amount, character, and source of any Section 987 gain or loss.  These regulations are generally effective for tax years beginning in 2018, but taxpayers may apply the new rules starting in 2017.  The presentation will address the key provisions of the final, temporary and proposed regulations and address transitional considerations as taxpayers look to adopt the final regulations.

Colleen Zeller, Senior Manager, Ernst & Young LLP

Update on International Mergers and Acquisitions under Sec. 367

·         Application of U.S. targets with foreign subsidiaries and foreign multinationals acquiring U.S. targets

·         Working with the new rules for the transfer of foreign tangible and intangible assets - Secs 367(a) and 367(d)

·         International stock transfers and inversions under Sections 367(a) and Section 7874

·         Application of Sec. 367(b) to inbound and foreign-to-foreign stock transfers – deferral of recognition of Sec. 1248 E&P

·         Application of New Section 385 Regulations to intercompany debts

Kevin Brogan, Managing Director, KPMG LLP
Andrew Simmons, Senior Manager, KPMG LLP