Introduction to U.S. International Tax

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Introduction to U.S. International Tax

1,195.00 1,395.00

December 4-5, 2017 - Regus, One Market, Spear Tower, 36th floor, San Francisco, California, 94105. Phone: 415 293 8000

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. 

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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

Monday, December 4, 2017

8:00 AM - Registration and Continental Breakfast

8:45 AM – Overview of U.S. International Taxation Including Tax Reform

  • Understanding Worldwide vs. Territorial Tax Systems
  • Resident vs. Activity Based Tax
  • Taxation of foreign income on U.S. Corporations
  • U.S. Income and Sourcing Rules
  • Permanent Establishment Principles and Double Taxation
  • Claiming a Deduction or Credit on Foreign Income
  • Overview of President Trump's Business Tax Proposals

10:15 AM - Refreshment Break

10:30 AM - The Sourcing of Income including the Allocation and Apportionment of Expenses

  • Residence For Taxation
  • Income From Single and Mixed Sources
  • The Basic Rules of Allocation and Apportionment
  • The Apportionment of R&D Expenses
  • Asset Apportionment of Interest Expense

12:00 AM – Networking Luncheon

12:45 PM - Controlled Foreign Corporations (CFCs) and Subpart F Income including Passive Foreign Investment Companies (PFICs)

  • 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
    • PFICs

2:15 PM – Refreshment Break

2:30 PM - Understanding Foreign Tax Credits including Direct and Indirect Credits

  • Key concepts of the foreign tax credit
  • Taxes available for the credit
  • § 901 direct credits
  • § 902 indirect (deemed paid) credits and § 960
    • Tax Pools & E&P Pools
    • § 78 gross-up
    • Foreign tax credit limitation formula
    • Applying the foreign tax credit limitation formula for passive and general baskets
    • § 905 and Redeterminations

4:00 PM - The Importance of 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

5:00 PM - Seminar adjourns for the day

Tuesday, December 5, 2017

8:00 AM - Continental Breakfast

8:45 AM - Overview of Transfer Pricing Principles and Methods

  • 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

9:45 AM - Refreshment Break

10:00 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

11:30 AM – Income Tax Treaties and Permanent Establishments (PEs)

  • 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

12:45 PM - Luncheon

1:30 PM - Introduction to 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

3:00 PM Seminar Concludes

Conference Location

Networking Seminar 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