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International

From the program: Basics of International Taxation 2012

Recorded on: Jul. 25, 2012

Taken from the Web Program Basics of International Taxation recorded July, 2012 in New York. Lecture Topics  [01:23:54] Controlled Foreign Corporations (CFCs) and Subpart F  [01:23:54] 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 ...

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 ...

From the program: International Estate & Tax Planning 2012: Planning for the International Private Client

Released on: May. 22, 2012

Audio CD's from the program International Estate & Tax Planning 2012: Planning for the International Private Client, held April, 2012.

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.  ...