Introduction to U.S. International Tax

intro Phil copy.jpg
intro Phil copy.jpg

Introduction to U.S. International Tax

1,195.00 1,395.00

November 16-17, 2017 - Regus, 1500 Market Street, 12th Floor, East Tower, Philadelphia, Pennsylvania, 19102. Phone: 215 246-3400

Earn Up to 15 CPE/CLE Credits

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Learn the fundamentals of U.S. international taxation.  This seminar will provide a basic understanding of U.S. international tax codes and tax reporting requirements for U.S. corporations with operations abroad.   The goal of the corporate tax practitioner is to reduce U.S. taxes on foreign income while also complying with Internal Revenue Codes. Download Brochure

This seminar is intended for corporate controllers, tax managers, accountants, attorneys, and other corporate finance executives looking to develop an understanding of how the U.S. taxes income from foreign operations. No prerequisite is required for this introductory course with group live instruction. This program is transitional which is appropriate for newly admitted attorneys. Field of Study: Taxes     Earn Up to 15 CPE/CLE Credits

Thursday, November 16, 2017

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
  • Permanent establishment principles and double taxation
  • Claiming a deduction or credit for foreign income taxes

10:15 AM - Refreshment Break

10:30 AM - Source of Income, Allocation and Expense Apportionment

  • Residence For Taxation
  • Income From Single and Mixed Sources
  • Establishing Foreign Title Passage
  • Tax Planning to Create or Increase Foreign Source Income
  • The Basic Rules of Allocation and Apportionment
  • The Apportionment of R&E Expenses
  • Asset Apportionment of Interest Expense
  • Tax Planning in Expense Apportionment

12:00 AM – Networking Luncheon

12:30 PM - Controlled Foreign Corporations (CFCs), Passive Foreign Investment Companies (PFICs) and Subpart F Income

  • 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
  • Calculating the Section 960 Credit for Deemed Inclusions
  • Previously Taxed Income

2:15 PM – Refreshment Break

2:30 PM - The Foreign Tax Credit

  • Key concepts of the foreign tax credit
  • Taxes available for the credit
  • § 901 direct credits
  • § 902 indirect (deemed paid) credits and § 960
  • 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

5:15 PM - Seminar adjourns for the day

    Friday, November 17, 2017

    8:30 AM - Continental Breakfast

    9:00 AM - Earnings and Profits

    • Earnings and profits (“E&P”) generally
    • Common E&P adjustments
    • The steps in preparing an E&P study
    • Preparing a computation of E&P pre-1987
    • Preparing a computation of E&P post-1986
    • Practical issues in calculating E&P
    • The importance of E&P in international tax

    10:15 AM - Refreshment Break

    10:30 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

    12:00 PM - Luncheon

    12:45 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

    2:00 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

    3:30 PM Seminar Concludes

    Seminar Location

    Seminars c/o Regus,

    1500 Market Street, 12th Floor, East Tower, Philadelphia, Pennsylvania, 19102, United States Phone: 215 246-3400

    Hotel accommodations are at your discretion we suggest: Sonesta Hotel Philadelphia, 1800 Market Street, Philadelphia, PA 19103. Reservations:  1-800-Sonesta or 215-561-7500