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Tax

International

Recorded on: Jul. 25, 2012

Taken from the Web Program Basics of International Taxation Recorded July, 2012 in New York Controlled Foreign Corporations (CFCs) and Subpart F [01:24:37] Overview of rules addressing controlled foreign corporations Maintaining deferral in basic supply chain structures Effective repatriation planning post 960(c) anti-hop-scotch rule Prospects for new guidance The purchase price of this segment includes the following article(s) ...

Recorded on: Feb. 5, 2013

Taken from the Web Program International Tax Issues 2013 Recorded January, 2013 in New York Cross Border M&A Planning [01:02:55] Acquisitions of foreign targets Acquisition of U.S. targets with foreign subsidiaries Foreign multinationals acquiring U.S. targets Section 367 developments Section 7874 developments Maximizing use of foreign cash to fund acquisitions The purchase price of this segment includes the ...

Recorded on: May. 16, 2012

Taken from the briefing Transfer Pricing: Managing Risks in Light of New IRS Enforcement Initiatives recorded May, 2012. The phenomenon of increasingly global business enterprises with valuable intangible property exposes companies to transfer pricing enforcement by different countries around the world.  Government taxing authorities are becoming more aggressive in enforcing transfer pricing rules as they move to protect their tax bases.  ...