Hot Issues in U.S. International Tax

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Hot Issues in U.S. International Tax


December 14-15, 2017 - Regus, One Market, Spear Tower, 36th floor, San Francisco, California, 94105. Phone: 415 293 8000

Earn Up to 13.5 CPE/CLE Credits

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. 

More than 30 years after enactment of the Tax Reform Act of 1986, President Trump and Congress have an opportunity to provide more competitive US business tax rates, modernized international tax rules, and significant simplification for both business and individual taxpayers. Tax reform legislation has the potential to affect significantly business and individual economic decision making, including how and where to invest resources both within the United States and globally.

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 12 CPE/11.5CLE Credits

Thursday, December 14, 2017

8:30 AM Registration

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

  • Overview of the proposed changes to territorial tax system
  • How expense apportionment affects credits foreign taxes and deduction of U.S. expenses
  • Selecting the best apportionment method - gross-to-gross v. factual apportionment
  • Section 861: Interest Expense
  • Section 861: R&D Expense  Other Deductions

10:45 AM Break

11:00 AM Foreign Tax Credits & Tax Reform

  • Foreign Tax Credits and Tax Reform (House Bill)
  • Indirect Credit (Sections 902 and 960)
  • Section 901 Statutory Anti-Abuse Rules (Section 901 (k), (I), (m))
  • FTC Planning - Repatriating FTCs
  • Regulatory Developments (Section 901 and 909)

12:30 PM Break for Lunch

1:30 PM Controlled Foreign Corporations & Subpart F Income Update

  • Identifying CFCs and “U.S. Shareholders”
  • Subpart F Overview
  • Understanding Foreign Personal Holding Company Income and Exceptions
  • Working with the branch rules for foreign sales and manufacturing activities
  • Avoiding investments in U.S. property by first or lower-tier CFCs
  • Tax Reform Update

3:00 PM Break

3:15 PM
Transfer Pricing Developments & BEPS Update

  • Update on recent legislative proposals as they relate to transfer pricing
  • Update on country-by-country (CbC) reporting regulations, changes to Section 482 aggregation rules and the treatment to outbound transfer under sections 367 and 721
  • Recent judicial development in cost sharing and intellectual property
  • Update on BEPS and transfer pricing )OECD Actions 7, 8-10)
  • Impact of IRS administrative changes on transfer pricing, APAs and competent authority cases

5:00 PM Meeting Adjourns for the Day

Friday, December 15, 2017

8:30 AM Registration

9:00 AM New Section 987 Regulations

  • Background
  • Summary of key changes
  • Overview of final and temporary regulations
  • Transaction rules and effective date
  • What you should do next

10:30 AM Break

10:45 AM 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 recognition of Sec. 1248 E&P
  • Application of Section 385 Regulations to intercompany debts

12:45 PM Questions & Answers

1:00 PM Conference Concludes

Conference Location:

Networking Seminars Conference Room c/o Regus, One Market, Spear Tower, 36th floor, San Francisco, California, 94105. Phone: 415 293 8000

Hotel accommodations are at your discretion, we suggest:

Hyatt Regency San Francisco, 5 Embarcadero Center, San Francisco, CA 94111 Phone: (415) 788-1234
Room rates starting at $289 plus taxes.