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 new program, we assembled some of the world’s leading tax experts to discuss the current rules of U.S. international taxation. We will describe how these rules work and focus upon their impact on financings, mergers, acquisitions and other commercial activities. In addition, we will analyze legislative proposals that have the potential to change these rules and discuss the likely impact of such changes on global business operations.
Lecture Topics [Total time 12:41:43]
Segments with an asterisk (*) are available only with the purchase of the entire program.
- Introduction and Opening Remarks* [00:03:14]
Linda E. Carlisle
- Controlled Foreign Corporations (CFCs) and Subpart F [01:23:54]
Rocco V. Femia, Phyllis E. Marcus, Jeffrey G. Mitchell
- M&A and Section 367 [01:14:43]
Michael L. Schultz, Gregory R. Walker, Robert B. Williams, Jr.
- Foreign Tax Credits [01:12:34]
Ginny Y. Chung, Barbara A. Felker, Elena V. Romanova, Carol P. Tello
- Foreign Investment in Real Property Tax Act (FIRPTA) Investments [01:12:57]
Guy A. Bracuti, David A. Levine
- Transfer Pricing and Section 482 [01:16:05]
Mary C. Bennett, Michael McDonald, Holly K. McClellan, Steven C. Wrappe
- Tax Treaties [01:13:10]
Arlene S. Fitzpatrick, John L. Harrington, Catherine G. Schultz, J. David Varley
- Passive Foreign Investment Companies (PFICs) [01:12:41]
Ethan A. Atticks, Kimberly S. Blanchard, Barbara E. Rasch
- Foreign Account Tax Compliance Act (FACTA) and Foreign Bank and Financial Accounts (FBAR) Provisions [01:15:10]
William J. Corcoran, Jeremy M. Naylor, Michael H. Plowgian, John M. Grimes
- Foreign Currency Transactions [01:19:22]
Douglas E. Chestnut, Mark E. Erwin, Richard G. Larkins
- Possible Legislative Changes to U.S. International Tax Rules [01:17:53]
E. Ray Beeman, Kevin M. Levingston, Kristeen R. Witt, Linda E. Carlisle
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
Rocco V. Femia
- A Primer on Section 367: Basic Rules and Policies
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
Guy A. Bracuti
- Transfer Pricing and Section 482: An Overview of U.S. Transfer Pricing Rules
Mary C. Bennett, Holly K. McClellan, Michael McDonald, Steven C. Wrappe
- Overview of U.S. Tax Treaties
John L. Harrington
- Results to the 2011 NFTC Tax Treaty Survey
Catherine G. Schultz
- An Introduction to PFICs
Kimberly S. Blanchard, Ethan A. Atticks, Barbara E. Rasch
- Foreign Account Tax Compliance Act (FACTA): Current Law, Proposed Regulations and Reporting and Withholding Obligations
Jeremy M. Naylor
- Statutory Fundamentals of the Taxation of Foreign Currency Transactions
Richard G. Larkins, Douglas E. Chestnut
- Possible Legislative Changes to U.S. International Tax Rules
Linda E. Carlisle, Kevin M. Levingston, E. Ray Beeman, Kristeen R. Witt
- Foreign Investment in Real Property Tax Act (FIRPTA) Investments (PowerPoint Slides)
Guy A. Bracuti
- Overview of U.S. Tax Treaties (PowerPoint Slides)
John L. Harrington
- An Introduction to PFICs (PowerPoint Slides)
Kimberly S. Blanchard, Ethan A. Atticks, Barbara E. Rasch
- Possible Legislative Changes to U.S. International Tax Rules (PowerPoint Slides)
Linda E. Carlisle, Kevin M. Levingston, E. Ray Beeman, Kristeen R. Witt
- Index to Basics of International Taxation 2012
Presentation Material
- Controlled Foreign Corporations (CFCs) and Subpart F
Rocco V. Femia, Phyllis E. Marcus, Jeffrey G. Mitchell
- M&A and Section 367
Michael L. Schultz,Gregory R. Walker,Robert B. Williams, Jr.
- Foreign Tax Credits
Ginny Y. Chung, Barbara A. Felker, Elena V. Romanova, Carol P. Tello
- Foreign Investment in Real Property Tax Act (FIRPTA) Investments
Guy A. Bracuti, David A. Levine
- Transfer Pricing and Section 482
Mary C. Bennett, Michael McDonald, Holly K. McClellan, Steven C. Wrappe
- Tax Treaties
Arlene S. Fitzpatrick, John L. Harrington, Catherine G. Schultz, J. David Varley
- Passive Foreign Investment Companies (PFICs)
Ethan A. Atticks, Kimberly S. Blanchard, Barbara E. Rasch
- Foreign Account Tax Compliance Act (FACTA) and Foreign Bank and Financial Accounts (FBAR) Provisions
William J. Corcoran, Jeremy M. Naylor, Michael H. Plowgian, John M. Grimes
- Foreign Currency Transactions
Douglas E. Chestnut, Mark E. Erwin, Richard G. Larkins
- Foreign Currency Transactions
Richard G. Larkins
- Possible Legislative Changes to U.S. International Tax Rules
E. Ray Beeman, Kevin M. Levingston, Kristeen R. Witt, Linda E. Carlisle
Chairperson(s)
Speaker(s)
E. Ray Beeman(invited) ~ Tax Counsel and Special Advisor for Tax Reform, Committee on Ways and Means, U.S. House of Representatives
Ginny Y. Chung ~ Attorney-Advisor; Office of Tax Policy, U.S. Department of the Treasury
Mark E. Erwin ~ Senior Technician Reviewer, Branch 5; Office of the Chief Counsel (International), Internal Revenue Service
Barbara A. Felker ~ Chief, Branch 3; Office of the Associate Chief Counsel (International), Internal Revenue Service
David A. Levine(invited) ~ Attorney, Branch 4; Office of the Associate Chief Counsel (International), Internal Revenue Service
Holly K. McClellan ~ Tranfer Pricing Leader, Tax Counsel, General Electric Capital Corporation
Michael McDonald ~ Finacial Economist, Business & International Taxation Division; Office of Tax Policy, U.S. Department of the Treasury
Jeffrey G. Mitchell ~ Chief, Branch 2; Office of the Associate Chief Counsel (International), Internal Revenue Service
Michael H. Plowgian ~ Senior Adviser, Base Erosion and Profit Shifting (BEPS), Organisation for Economic Co-operation and Development (OECD)
Barbara E. Rasch(invited) ~ Attorney, Branch 2; Office of the Associate Chief Counsel (International), Internal Revenue Service
Elena V. Romanova ~ Director, Head of Consumer and Private Bank Tax Advisory, Citigroup
J. David Varley(invited) ~ Senior Manager, Treaty Assistance and Interpretation; Large Business & International Division (LB&I), Internal Revenue Service
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 Carolina8, 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
The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.
*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.