This is a webcast of the live New York session.Why you should attend
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.
At this program, some of the world’s leading tax experts will discuss the current rules of U.S. international taxation. Each panel will focus upon a distinct international tax issue and describe how the U.S. tax rules address this issue. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities. In addition, we will analyze legislative proposals that may change these rules and discuss the likely impact of such changes on global business operations.
What you will learn
- The impact of Subpart F on global businesses
- The background, purpose and history of foreign tax credits
- The mechanics and significance of tax treaties
- The possibility of U.S. international tax reform
- Transfer pricing principles and their use in transfer of goods, services and intangibles
- Reporting and withholding requirements under the Foreign Account Tax Compliance Act (FATCA)
- How to recognize Passive Foreign Investment Companies (PFICs)
Who should attend
Corporate, law firm and accounting firm professionals that consider cross border transactions and need a working knowledge of relevant U.S. international tax rules, and government attorneys who want to stay on top of what’s happening in the international tax arena will benefit from attending this program.
PLI Group Discounts
Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.
PLI Can Arrange Group Viewing to Your Firm
Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.
Cancellations
All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.
All times are E.D.T.
Day One: 9:00 a.m. - 5:00 p.m. (E.D.T.)
Morning Session: 9:00 a.m. - 12:00 p.m. (E.D.T.)
9:00 Introduction and Opening Remarks
Linda E. Carlisle
9:15 Controlled Foreign Corporations (CFCs) and Subpart F
- 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
Layla J. Aksakal, Phyllis E. Marcus
10:30 Networking Break
10:45 M&A and Section 367
- Outbound Section 351 exchanges and reorganizations
- Imputed royalties on outbound transfers of intangibles
- Outbound spin-offs and liquidations
- Inbound liquidations and reorganizations
- Foreign-to-foreign reorganizations and liquidations and their effect on tax attributes such as deficits and foreign taxes
Eileen Marshall, Michael L. Schultz, Gregory R. Walker
12:00 Lunch
Afternoon Session: 1:00 p.m. - 5:00 p.m. (E.D.T.)
1:00 Foreign Tax Credits
- Purpose, history, and background of foreign tax credits
- What is a creditable tax?
- Claiming Section 901 credits/Section 902 indirect credits/Section 960 credits
- Mechanics of Section 904
- Statutory and regulatory limits on foreign tax credit claims
Elena V. Romanova, Carol P. Tello
2:15 Foreign Investment in Real Property Tax Act (FIRPTA) Investments
- Reasons for the enactment of FIRPTA
- FIRPTA taxation overview
- Relevant definitions: U.S. real property interest, U.S. real property holding corporation, effectively connected income, disposition
- Section 1445 withholding
- Special considerations for non-recognition transactions
Chris Bowers, Guy A. Bracuti
3:30 Networking Break
3:45 Transfer Pricing and Section 482
- Introduction to Section 482 and the arm’s length principle
- Comparability analyses
- Transfer pricing methods and their use
- Special considerations for services, intangibles and cost-sharing agreements
- Documentation, advance pricing agreements, and mutual agreement procedures
Natalie Hodapp, Steven C. Wrappe
5:00 Adjourn
Day Two: 9:00 a.m. - 5:00 p.m. (E.D.T.)
Morning Session: 9:00 a.m. - 1:00 p.m. (E.D.T.)
9:00 Tax Treaties
- Overview of tax treaties: what they are and how they fit into U.S. domestic tax law
- General provisions of U.S. tax treaties
- How the Treasury Department negotiates tax treaties: prioritizing countries and treaties; problem areas; likely future developments
- Resolution of disputes under tax treaties and the role of the competent authority process
- Importance of tax treaties to companies and tax planning
John L. Harrington, Catherine G. Schultz
10:15 Passive Foreign Investment Companies (PFICs)
- How to recognize a PFIC
- The three PFIC taxation regimes
- Making PFIC elections
- PFIC reporting rules
Kimberly S. Blanchard, Andrew P. Solomon
11:30 Networking Break
11:45 Foreign Account Tax Compliance Act (FATCA) and Foreign Bank and Financial Accounts (FBAR) Provisions
- FATCA – What does it do?
- Reporting and withholding requirements under FATCA
- Steps to implementation - interpreting recent guidance
- FBAR and specified foreign financial assets reporting – the basics
- What “accounts” are included? What are excluded?
- Forms and deadlines
William J. Corcoran, John M. Grimes, Jeremy M. Naylor, Michael H. Plowgian
1:00 Lunch
Afternoon Session: 2:15 p.m. - 5:00 p.m. (E.D.T.)
2:15 Foreign Currency Transactions
- Determining functional currency
- Branch transactions
- Treatment of foreign currency transactions
- Currency hedging and integration
Douglas E. Chestnut, Richard G. Larkins, Mark H. Price
3:30 Networking Break
3:45 Possible Legislative Changes to U.S. International Tax Rules
- Overview of Ways & Means Committee and Senate Finance Committee International tax reform proposals
- Impact of “territorial” taxation of business transactions
- Overall prospects for international tax reform
E. Ray Beeman (invited), Linda E. Carlisle, John L. Harrington, Kevin M. Levingston, Kristeen R. Witt
5:00 Adjourn
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
Natalie Hodapp ~ Supervisory Tax Law Specialist; Transfer Pricing Practice - Territory East, Internal Revenue Service
Michael H. Plowgian ~ Senior Adviser, Base Erosion and Profit Shifting (BEPS), Organisation for Economic Co-operation and Development (OECD)
Elena V. Romanova ~ Director, Head of Consumer and Private Bank Tax Advisory, Citigroup
Program Attorney(s)
PLI makes every effort to accredit its Live Webcasts. Please check the CLE Calculator above for CLE information specific to your state.
PLI's Live Webcasts are approved for MCLE credit (
unless otherwise noted in the product description) in the following states/territories: Alabama, Alaska, Arkansas, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho*, Illinois, Indiana
1, Iowa*, Kansas*, Kentucky*, Louisiana, Maine*, Minnesota, Mississippi, Missouri, Montana, Nebraska, North Carolina, North Dakota, New Hampshire*, New Jersey, New Mexico, Nevada, New York
2, Ohio
3, Oklahoma, Oregon*, Pennsylvania
4, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia
5, Virgin Islands, Washington, West Virginia, Wisconsin, and Wyoming*.
*PLI will apply for credit upon request.
Arizona: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.
Arkansas and Oklahoma: Audio-only live webcasts are not approved for credit.
1Indiana: Considered a distance education course. There is a 6 credit limit per year.
2New York: Newly admitted attorneys may not take non-transitional course formats such as on-demand audio or video 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.
3Ohio: To confirm that the live webcast 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 biennial 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.
4 Pennsylvania: A live webcast may be viewed individually or in a group setting. Credit may be granted to an attorney who views a live webcast individually. There is a 4.0 credit limit per year for this type of viewing. A live webcast viewed in a group setting receives live participatory credit if the program is open to the public and advertised at least 30 days prior to the program. Live webcasts viewed in a group setting that do not advertise at least 30 days prior the program will be considered "in-house", and therefore denied credit.
5Virginia: All distance learning courses are to be done in an educational setting, free from distractions.
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.
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, refer to your state CLE website or call Customer Service at (800) 260-4PLI (4754) or email: info@pli.edu.
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.