Impact of Tax Reform on International Business
Friday, December 7, 2018 - New York, NY

Early Registration is $895 until November 7th. Regular Registration is $995 per person. Groups of 3 or more Save $200 off each registrant with code GRP.

Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

Current issues, topics and legislation will be discussed. This seminar will provide the resources and information you need on the latest developments, strategies and techniques to represent and meet the needs of your clients or corporate filings. Attendees will have the opportunity to engage with our tax practitioners on topics related to understanding tax reform and the practical implications.

This course is for corporate tax, finance and accounting executives, CPAs, tax attorneys and counsel who are involved in corporate filing for both domestic and multinational corporations.  This is an intermediate level seminar and knowledge of international taxation and cross-border transactions are recommended prior to attending. There is no advance preparation for this group live seminar. Field of Study: Taxes   Earn Up to 7.5 CPE/CLE Credits

Friday, December 7, 2018

8:30 AM - Registration

9:00 AM - Tax Reform - Tax Cuts and Jobs Act

  • US Tax Reform---Global Impact and Responses

  • Interest Limitations

  • Transfer Pricing

  • Transparency and Disclosure

  • Use of Holding Companies

  • What’s All This Mean for Future Tax Audits

  • Special Deductions for Corporations

  • Other Jurisdiction Specific Noteworthy Items

Khiem Ting, Senior Manager/Director, KPMG LLP, Stamford

10:15 AM Break 

10:30 AM - Subpart F Income

  • Basics of Section 956 (Subpart F)

  • Dividends received deduction (DRD) under Section 1248

  • Subpart F income and Global Intangible Low Tax Income (GILTI)

  • Foreign Derived Intangible Income (FDII)

  • Participation Exemption

  • PFICs

12:15 PM - Luncheon

1:00 PM Foreign Tax Credit Baskets, Limintiations & Utilizations

  • Changes to the FTC Regime

  • Foreign Tax Credit Planning

  • Foreign Tax Credit Utilization

  • Post Section 965 PTI Distributions

  • Distributions of Untaxed E&P

David Merrick, Managing Director, PricewaterhouseCoopers LLP, New York

2:15 PM Break

2:30 PM Base Erosion and Anti-Abuse Tax and Other Transfer Pricing Issues

  • Overview of the Base erosion and anti-abuse tax (BEAT)

  • Beating the BEAT—Planning Options

  • Uncertainties and Potential for Relief

  • Effects on Intellectual Property

Brian Trauman, Principal, National Transfer Pricing Leader, KPMG LLP, New York

3:45 PM Break

4:00 PM State & Local Tax Reform Issues

  • The financial impact on the states

  • Conformity and non-conformity overview

  • State treatment of domestic issues

  • State treatment of foreign issues

  • Impact of Wayfair Decision

Sam Lee, Senior Manager, Deloitte Tax LLP, New YorkEffet of Tax Refomr on

Conference Location:

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Convene
780 Third Avenue,
Concourse Level 2,
New York, NY 10017



Recommended Hotels:

Hotel 48Lex New York, 17 Lexington Ave, New York, New York 10017 Phone: 212-888-3500

The Benjamin Hotel 125 East 50th Street, NY, NY 10022 Phone: 866-222-2365

The Hilton Garden Inn  206 East 52nd Street, New York, New York, 10022 Phone: 212-794-6000

Register Today! Early Registration of $895 Expires on November 7th.

Speaker Biographies

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Sam Lee is a Senior Manager in Deloitte’s Multistate Tax practice in New York.  Mr. Lee advises corporate clients on state and local tax matters, with an emphasis on multi-state income and franchise taxes.  Mr. Lee has served clients across various industries, including consumer products and retail, media and entertainment, manufacturing, telecommunications, and the energy and real estate sectors. His experience includes all aspects of state and local tax from planning and compliance to state tax controversy, with extensive experience in merger and acquisition planning, and strategic state tax planning involving business restructurings.  In particular, Mr. Lee has advised on numerous multinational operating model restructurings for consumer products and retail clients addressing state tax considerations in connection with domestic and cross border product flows, systems integration, state nexus profiles of foreign principal entities, and sourcing methodologies across buy/sell or value based fee models. Mr. Lee earned a JD from The George Washington University Law School, and his LL.M. in Taxation from New York University School of Law.

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David Merrick is Tax Managing Director, International Corporate Services at PricewaterhouseCoopers LLP in New York City. David’s principal practice areas are the US foreign tax credit and in international reorganizations and acquisitions. He began his career with the Office of the Chief Counsel, IRS, and was the principal author of the interest allocation regulations under section 864(e). In private practice, he has continued to focus on planning foreign remittances, managing foreign tax credit utilization, and optimizing the worldwide tax cost of corporate transactions. David received a JD from George Washington University.

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Khiem Ting is a Senior Manager/Director with KPMG LLP’s International Tax practice based in New York City. Khiem provides US international tax services to abroad range of clients including US and foreign multinational corporations, private equity firms and other alternative investment funds. Khiem has eleven years of Big Four accounting firm experience in practicing US international tax. He also has in-house tax experience. Before embarking on a career in public accounting, he served as MasterCard’s International Tax Director. Khiem’s tax practice covers all areas of US international tax including: US anti-deferral rules (Subpart F and PFICs); Cross-border transactions and restructurings; Cash repatriations; and foreign tax credits. He also is assisting clients on all aspects of US foreign tax reporting

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Brian Trauman is the U.S. National Transfer Pricing leader for KPMG’s Economic and Valuation Services (EVS) practice.  He was most recently the global head of KPMG’s Transfer Pricing Dispute Resolution practice. A significant part of Brian’s practice is helping clients manage and resolve disputes and respond to the challenges that come with transfer pricing controversies, whether related to intercompany pricing between countries or between U.S. states. Prior to joining KPMG, Brian was a partner in the tax controversy and transfer pricing practice of a multinational law firm, where he was responsible for assisting multinationals with a wide range of both U.S. and non-U.S. matters, including transfer pricing structures and supply chains, advance pricing agreements (APAs), mutual agreement procedures (MAPs), documentation, intercompany agreements, and audits, appeals, and litigation. His clients have included leading companies in such industries as the agricultural, automotive, chemical, consumer electronics, entertainment, finance, oil and gas, medical device, shipping, technology, and telecommunications sectors.

Brian has responded to state, federal and foreign information document requests, liaised with exam teams, drafted protests to notices of proposed adjustments, presented cases to appeals teams, and participated on litigation teams. In addition, he has interacted with Congress, the IRS, Treasury, foreign revenue authorities, and the OECD for changes to income tax code, regulations, and other guidance. Brian has also served as an attorney-advisor with the U.S. Tax Court. Brian earned his LL.M. from New York University; His JD with honors from Levin College, University of Florida; and his BSBA in Finance with honors from the University of Florida.