Hot Issues in U.S. International Taxation

HOT DC copy.jpg
HOT DC copy.jpg

Hot Issues in U.S. International Taxation


November 13-14, 2017 - Regus, 1050 Connecticut Avenue, NW, Suite 500, Washington, DC 20036 Phone: 202 772 3100

Earn Up to 13.5 CPE/CLE Credits

Early Registration valid until October 15, 2017.  Price will increase $200 after October 14th. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

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Networking Seminars is proud to announce our intermediate tax planning seminar in Washington, DC. This is for law, tax and accounting professionals who are involved in structuring cross border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and internal planning and in IRS audits and appeals of international issues; and tax attorneys who want to stay on top of what’s happening in the international tax arena.  Please Note: This seminar topics are subject to change with any new tax reform policy announcements

As more U.S. corporations look for tax advantages overseas, the U.S. international tax laws and proposed new regulations will have a greater impact on U.S. businesses and transactions, not to mention the new Trump administrations ideas and plans for international tax reform.

The international tax rules affect not only large U.S. and foreign-based multinationals, but also increasingly affect mid-sized and smaller firms, financing transactions, mergers and acquisitions, currency translations and other commercial activity.  As a result, a working knowledge of these international tax rules is importance to a wide variety of tax professionals.  This seminar is designed for those with experience in U.S. tax law and transactions at companies who we have significant cross-border activities. There is no advanced preparation, however, the prerequisite is an introductory course and knowledge of U.S. international tax law and cross-border transactions.  Field of Study: Taxes

Earn Up to 13.5 CPE/11.5CLE Credits

Monday, November 13, 2017

8:30 am Registration and Continental Breakfast

9:00 am International Tax Reform and Expense Apportionment Practice Update

  • Overview of the proposed international tax reform for U.S. multinationals
  • 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

10:30 am Break for Refreshments

10:45 am 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

Caren Shein, Managing Director, Deloitte Tax LLP

12:15 pm Luncheon

1:00 pm 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
  • Affirmative use of Subpart F
  • Avoiding investments in U.S. property by first or lower-tier CFCs

Jim Riedy, Partner, McDermott, Will & Emery LLP

2:45 pm Break for Refreshments

3:00 pm
Transfer Pricing & BEPS Developments

  • 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

David Canale, Global & Americas Leader, Transfer Pricing Controversy, Ernst & Young LLP

4:45 pm Meeting Adjourns for the Day

Tuesday, November 14, 2017

8:00 am Continental Breakfast

8:30 am
Final Regulations under Section 987

On 7 December, the Treasury and IRS issued the long-awaited final, temporary and proposed 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.  Both the final and temporary 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

David Golden, National Director, Ernst & Young LLP

10:00 am Refreshment Break

10:30 am International Tax Reform & the New Section 385 Regulations

·         On 13 October 2016, the US Treasury Department (the Treasury) and the Internal Revenue Service (the IRS) released final and temporary regulations under Internal Revenue Code Section 385 (TD 9790, the Final Regulations), which follow the release of extremely controversial proposed regulations by just six months (REG-108060-15, the Proposed Regulations). In response to comments, the Final Regulations significantly narrow the scope of the Proposed Regulations.

·         Like the Proposed Regulations, the Final Regulations target instruments issued to a member of the issuer’s “expanded group” that would otherwise constitute indebtedness for US federal tax purposes under common law principles. The Final Regulations establish extensive documentation requirements that must be satisfied for a debt instrument to constitute indebtedness for US federal tax purposes (the Documentation Rule) and recharacterize a debt instrument issued after 4 April 2016, as stock if the instrument is: (i) issued in one of a number of specified transactions (tainted transactions), or (ii) funds a tainted transaction (the Recharacterization Rule).

·         The presentation will also provide a general update on current proposals of U.S. tax reform by the House of Representatives.

12:00 pm Luncheon

1:00 pm
Update on Tax-Free International Mergers and Acquisitions under Sec. 367

  • Working with the new rules for the transfer of foreign tangible and intangible assets - Secs 367(a) and 367(d)
  • Using cash offshore to fund an acquisition of a U.S. target
  • International stock transfers and inversions under Sections 367(a) and/or 7874
  • Application of Sec. 367(b) to inbound and foreign-to-foreign stock transfers – deferral of negotiation of Sec. 1248 E&P
  • Application of Section 385 Regulations to intercompany debts

John Barrie, Partner, Bryan Cave LLP

2:45 pm Conference Concludes

Conference Location:

Networking Seminars Conference Room c/o Regus, Regus, 1050 Connecticut Avenue, NW, Suite 500, Washington, District of Columbia, 20036.  Phone: 202 772 3100

Hotel accommodations are at your discretion. We suggest:  The Mayflower Hotel, 1127 Connecticut Ave NW, Washington, DC 20036 Phone: (202) 347-3000