In a global business, the tax laws of the United States may impact transactions regardless of where the transactions take place. A working knowledge of the U. S. international tax rules is, therefore, of paramount importance to a wide variety of tax and corporate professionals.
In this program, some of the world’s leading tax experts will discuss the current rules of U.S. international taxation. Each panel will focus upon a distinct international tax issue and describe how the U.S. tax rules address this issue. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities. In addition, we will analyze legislative proposals that may change these rules and discuss the likely impact of such changes on global business operations.
Lecture Topics [Total time 012:52:21]
Segments with an asterisk (*) are available only with the purchase of the entire program.
- Introduction and Opening Remarks* [00:04:04]
Linda E. Carlisle
- Controlled Foreign Corporations (CFCs) and Subpart F [01:23:30]
Phyllis E. Marcus, Layla J. Aksakal, Arlene S. Fitzpatrick
- M&A and Section 367 [01:16:06]
Michael L. Schultz, Gregory R. Walker, Eileen Marshall
- Foreign Tax Credits [01:16:42]
Carol P. Tello, Elena V. Romanova
- Foreign Investment in Real Property Tax Act (FIRPTA) Investments [01:14:27]
Guy A. Bracuti, Chris Bowers
- Transfer Pricing and Section 482 [01:17:18]
Steven C. Wrappe, Natalie Hodapp
- Tax Treaties [01:15:02]
Catherine G. Schultz, John L. Harrington, J. David Varley, Arlene S. Fitzpatrick
- Passive Foreign Investment Companies (PFICs) [01:13:31]
Kimberly S. Blanchard, Andrew P. Solomon
- Foreign Account Tax Compliance Act (FACTA) and Foreign Bank and Financial Bar Accounts (FBAR) [01:15:32]
William J. Corcoran, Jeremy M. Naylor, Michael H. Plowgian, John M. Grimes
- Foreign Currency Transactions [01:18:03]
Douglas E. Chestnut, Richard G. Larkins, Jonathan R. Zelnik
- Possible Legislative Changes to U.S. International Tax Rules [01:18:06]
Linda E. Carlisle, John L. Harrington, Brion D. Graber, Jefferson P. Vanderwolk
The purchase price of this Web Program includes the following articles from the Course Handbook available online:
- Outline of Subpart F Anti-Deferral Regime Applicable to U.S. Controlled Foreign Corporations (April 26, 2013)
Layla J. Aksakal, Rocco V. Femia
- A Primer on Section 367: Basic Rules and Policies (April 26, 2013)
Michael L. Schultz
- An Introduction to the Foreign Tax Credit
Carol P. Tello
- FIRPTA
Guy A. Bracuti
- Infrastructure and Alternative Energy in the 21st Century: Does 20th Century U.S. Tax Policy Leave Us Tilting at Windmills? 40 TMIJ 3, 01/14/2011
Guy A. Bracuti
- Transfer Pricing and Section 482: An Overview of U.S. Transfer Pricing Rules
Melody H. Leung, Steven C. Wrappe
- Overview of U.S. Tax Treaties (April 26, 2013)
John L. Harrington
- Tax Treaties and Their Importance to the United States
Catherine G. Schultz
- An Introduction to PFICS
Andrew P. Solomon, Barbara E. Rasch(invited), Kimberly S. Blanchard
- New PFIC Guidance Provided: But More Remains to Be Done, 38 Tax Mgmt. Intl. J. 675 2009 (December 11, 2009)
Carol P. Tello, Christopher Ocasal
- The Foreign Account Tax Compliance Act (FATCA): A Summary of The Law, The Final Regulations and The Intergovernmental Agreements
Jeremy M. Naylor
- Statutory Fundamentals of the Taxation of Foreign Currency Transactions
Douglas E. Chestnut, Richard G. Larkins
- Tax Reform: Searching for a Fast Track to an Unknown Destination (March 4, 2013)
John L. Harrington
- General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals (April 2013)
- Technical Explanation of the Ways and Means Discussion Draft Provisions to Establish a Participation Exemption System for the Taxation of Foreign Income (October 26, 2011)
- Foreign Investment in Real Property Tax Act (Firpta) Investments (Powerpoint Slides)
Guy A. Bracuti
- Transfer Pricing and Section 482 (Powerpoint Slides)
Melody H. Leung, Steven C. Wrappe
- Overview of U.S. Tax Treaties (Powerpoint Slides)
John L. Harrington
- An Introduction to PFICS (New York City Powerpoint Slides)
Andrew P. Solomon, Barbara E. Rasch(invited), Kimberly S. Blanchard
- An Introduction to PFICS (San Francisco Powerpoint Slides)
Barbara E. Rasch(invited), Christopher Ocasal, Ethan A. Atticks
- Possible Legislative Changes to U.S. International Tax Rules (Powerpoint Slides)
E. Ray Beeman(invited), John L. Harrington, Kevin M. Levingston, Kristeen R. Witt, Linda E. Carlisle
Presentation Material
- Subpart F Income
Phyllis E. Marcus, Layla J. Aksakal, Arlene S. Fitzpatrick
- M&A and Section 367
Michael L. Schultz, Gregory R. Walker, Eileen Marshall
- Introduction to the Foreign Tax Credit
Carol P. Tello, Elena V. Romanova
- FIRPTA
Guy A. Bracuti, Chris Bowers
- Transfer Pricing and Section 482
Steven C. Wrappe, Natalie Hodapp
- Tax Treaties
John L. Harrington
- PFICs
Kimberly S. Blanchard, Andrew P. Solomon
- FATCA and FBAR
William J. Corcoran, Jeremy M. Naylor, Michael H. Plowgian, John M. Grimes
- Foreign Currency Transactions
Douglas E. Chestnut, Richard G. Larkins, Jonathan R. Zelnik
- Possible Legislative Changes to U.S. International Tax Rules
Linda E. Carlisle
Chairperson(s)
Speaker(s)
Arlene S. Fitzpatrick ~ Attorney-Advisor; Office of the International Tax Counsel, U.S. Department of the Treasury
Natalie Hodapp ~ Supervisory Tax Law Specialist; Transfer Pricing Practice - Territory East, Internal Revenue Service
Michael H. Plowgian ~ Senior Adviser, Base Erosion and Profit Shifting (BEPS), Organisation for Economic Co-operation and Development (OECD)
Elena V. Romanova ~ Director, Head of Consumer and Private Bank Tax Advisory, Citigroup
J. David Varley ~ Senior Manager, Treaty Assistance and Interpretation; Large Business & International Division (LB&I), Internal Revenue Service
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On-Demand Web Programs and Segments are approved in:
Alabama1, Alaska, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho*, Illinois , Iowa2*, Kansas, Kentucky*, Louisiana, Maine*, Mississippi, Missouri3, Montana, Nebraska, Nevada, New Hampshire4, New Jersey, New Mexico5, New York6, North Carolina7, North Dakota, Ohio8, Oklahoma9, Oregon*, Pennsylvania10, Rhode Island11, South Carolina, Tennessee12, Texas, Utah, Vermont, Virginia13, Washington, West Virginia, Wisconsin14 and Wyoming*.
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Minnesota approves live webcasts ONLY
Please Note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. PLI programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.
*PLI will apply for credit upon request. Louisiana and New Hampshire: PLI will apply for credit upon request for audio-only on-demand web programs.
1Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.
2Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.
3Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.
4New Hamphsire: The approval is for three years from recorded date.
5New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.
6New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web Programs or live Webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.
7North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.
8Ohio: To confirm that the web program has been approved, please refer to the list of Ohio’s Approved Self Study Activities at http://www.sconet.state.oh.us. Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.
9Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.
10Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.
11Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.
12Tennessee: The approval is for the calendar year in which the live program was presented.
13Virginia: All distance learning courses are to be done in an educational setting, free from distractions.
14Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.
Running time and CLE credit hours are not necessarily the same. Please be aware that many states do not permit credit for luncheon and keynote speakers.
If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.
Note that some states limit the number of credit hours attorneys may claim for online CLE activities, and state rules vary with regard to whether online CLE activities qualify for participatory or self-study credits. For more information, call Customer Service (800) 260-4PLI (4754) or e-mail info@pli.edu.