On-Demand Learning

Tax

International

From the program: Basics of International Taxation 2013

Recorded on: Jul. 26, 2013

Taken from the Web Program Basics of International Taxation 2013 recorded July, 2013 in New York.Lecture Topics  [01:23:30]Controlled Foreign Corporations (CFCs) and Subpart F  [01:23:30] History and policies underlying Subpart F rules Key definitions and foundational concepts Required inclusions under Subpart F rules Treatment of distributions from CFCs Consequences of dispositions and liquidations of CFCs The purchase price ...

Recorded on: Dec. 21, 2011

AMY TAUB: Thank you. Greetings. My name is Amy Taub and I am a program attorney with PLI. I would like to welcome you to today's briefing, Computing Tax in the Cloud, State and International Implications. Before we begin, I have some administrative announcements. This briefing will be one hour in length. Please feel free to send questions at any time during the briefing. Please remember that you have access to materials for this briefing via the course ...

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 ...

Released on: Nov. 1, 2012

Taken from the briefing FATCA: The Deadline Looms... Will You Be Ready? recorded October, 2012. In the wake of the massive criminal tax prosecutions of UBS and other foreign firms by the Department of Justice in the late 2000s, Congress enacted FATCA to combat tax evasion by U.S. persons and to deter the facilitation of tax evasion by foreign financial institutions (“FFIs”).  To achieve these goals, FATCA requires that foreign ...

Recorded on: Mar. 22, 2012

SANFORD C. PRESANT: OK. Our next speakers are Michael Hirschfeld and Gino Bianchini. Michael Hirschfeld, former partner of mine at-- MICHAEL HIRSCHFELD: [INAUDIBLE]. SANFORD C. PRESANT: Where was it? Where was it, OK? Tell me. OK. Oh, Gino. Perfect. Wonderful. OK. SPEAKER 1: --and Presant. SANFORD C. PRESANT: He's a partner in the New York office of Dechert LLP. He specializes in international corporate workout partnership matters. He's Vice President ...

Recorded on: Jul. 22, 2013

Taken from the briefing Growing Criminal Risks of Intermediaries for Cross-Border Financial Crimes recorded July, 2013.In the last couple of decades the U.S. and the world have experienced growing prosecutions of intermediaries for cross-border financial crimes.   A U.S. bank was convicted by a Spanish court for moving money in the Pinochet criminal investigation instead of freezing it.  The U.S. and State of New York have ...

From the program: International Estate & Tax Planning 2013

Released on: May. 7, 2013

Individuals with connections to more than one country - international private clients - need sophisticated succession and tax planning advisors to help them navigate a complex and sometimes treacherous legal, tax and regulatory environment. These clients include U.S. persons with assets or beneficiaries outside the United States, as well as non-U.S. persons with U.S. connections. Their advisors must view a client’s specific circumstances ...

From the program: Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2013 (New York)

Recorded on: May. 31, 2013

Taken from the Web Program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2013 (New York City) recorded May, 2013 in New York.Lecture Topics  [01:47:53]International Joint Venture Issues - Outbound and Inbound General Joint Venture Tax Issues/"Check-the-Box" Planning [01:47:53] General review of benefits/detriments in using U.S. or foreign tax partnership vs. corporate structure in ...