As the world’s economies grow increasingly integrated, the international tax laws of the U.S. impact a greater percentage of businesses and transactions. These 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, and other commercial activity. As a result, a working knowledge of these international tax rules is of paramount importance to a wide variety of tax professionals.
In this year’s program we assembled some of the world’s leading experts and senior government officials to discuss the complex rules of U.S. international taxation. We will focus upon both operational and transactional implications of these rules, and will describe the application of the rules to both U.S. and foreign-based entities.
Lecture Topics [Total time 06:16:39]
Segments with an asterisk (*) are available only with the purchase of the entire program.
- Introduction and Opening Remarks* [00:02:14]
Michael A. DiFronzo
- Inbound Issues and Planning [01:06:37]
Kimberly S. Blanchard, Jesse F. Eggert, Peter A. Glicklich, Oren Penn
- Managing Offshore Cash [01:01:11]
William S. Dixon, L. G. Chip Harter, Kimberly T. Majure, Gregory R. Walker
- Cross Border M&A Planning [01:02:08]
Peter H. Blessing, Hal Hicks, T. Timothy Tuerff
- Foreign Tax Credit & Subpart F Developments [01:49:13]
James P. Fuller, John D. McDonald, Lowell D. Yoder
- Recent Developments on Transfer Pricing [01:15:16]
David J. Canale, Rocco V. Femia, Samuel M. Maruca, Thomas M. Zollo
The purchase price of this Web Program includes the following articles from the Course Handbook available online:
- Application of Fiscal Transparency Principles to Treaty Limitations on the Branch Profits Tax
Steve Nauheim, Susan J Conklin, Oren Penn
- Pepsico Puerto Rico, Inc. Et Al. v. Commissioner, TC Memo 2012-269, Code Sec(s) 385
Kimberly S. Blanchard
- New York State Bar Association Tax Section Report on IRS Announcement 2008-115 on FIRPTA Treatment of Rights Granted by a Governmental Unit
Kimberly S. Blanchard
- Section 892 Controlled Commercial Entities: The USRPHC Trap
Kimberly S. Blanchard
- Infrastructure and FIRPTA: Advanced Notice of Proposed Rulemaking
Kimberly S. Blanchard
- FIRPTA in the 21st Century--Installment Two: The 5% Public Shareholder Exception
Kimberly S. Blanchard
- FIRPTA in the 21st Century--Installment Three: FIRPTA and Foreign PTPs
Kimberly S. Blanchard
- FIRPTA in the 21st Century--Installment Six: FIRPTA Withholding Where a Section 892 Investor Is a Partner
Kimberly S. Blanchard
- Code Sec. 988 and the Nonrecognition Provisions--Part I: Transfers of Foreign Currency Loans Receivable
L. G. Chip Harter
- Code Sec. 988 and the Nonrecognition Provisions--Part II: Assumptions of Foreign Currency Denominated Liabilities
L. G. Chip Harter, Rebecca E. Lee
- U.S. Tax Consequences of International Acquisitions
James P. Fuller
- The Empire Strikes Back (Again)--Killer Bs, Deadly Ds and Code Section 367 As the Death Star Against Repatriation Rebels
Hal Hicks
- If You Build It (or Contract to Build It) They Will Come: Final and Temporary Regulations Under Code Section 954(d) Address the Manufacturing Exception and Branch Rules
Hal Hicks
- Sandwich Structures: The IRS Illuminates the Application of DRD and Other Provisions
Hal Hicks, Eric B. Sensenbrenner, Daniel M. McCall
- Subpart F Sales & Services Planning
Lowell D. Yoder
- Foreign Tax Credit Developments
James P. Fuller
- U.S. Transfer Pricing Rules and Intangible Property
Rocco V. Femia
- Two Key Priorities That Will Enhance the Mutual Agreement Procedure
Steven C. Wrappe, David J. Canale
- The Final Cost Sharing Regulations Attempt to Tighten the Loose Screws
Thomas M. Zollo
- The Transfer of Workforce in Place to a Foreign Corporation
Thomas M. Zollo
- Index to International Tax Issues 2013
Presentation Material
- Inbound Issues and Planning
Kimberly S. Blanchard, Jesse F. Eggert, Peter A. Glicklich, Oren Penn
- Managing Offshore Cash
William S. Dixon, L. G. Chip Harter, Kimberly T. Majure, Gregory R. Walker
- Cross-Border Acquisitions and Restructurings
Peter H. Blessing, Nicholas J. DeNovio, Hal Hicks, T. Timothy Tuerff
- Recent Developments in FTC Planning and Subpart F
James P. Fuller, John D. McDonald, Gretchen T. Sierra, Lowell D. Yoder
- Recent Developments in Transfer Pricing New York City (January 31, 2013)
David J. Canale, Rocco V. Femia, Samuel M. Maruca, Thomas M. Zollo
PLI makes every effort to accredit its On-Demand Web Programs and Segments. Please check the CLE Calculator above for CLE information specific to your state.
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*.
Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.
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.