Seminar  Seminar

Basics of International Taxation 2014


Select a Location:

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.

This year’s program will be led by international tax experts and feature a substantially revised schedule including new sessions on outbound investments, IRS reporting requirements and mobile employees. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the U.S. tax rules address the issues raised. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities.

What you will learn

  • The impact of Subpart F on global businesses
  • What blockers are and why they are used for outbound and inbound investments
  • The background, purpose and history of foreign tax credits
  • The mechanics and significance of tax treaties
  • Transfer pricing principles and their use in transfer of goods, services and intangibles
  • Reporting and withholding requirements in international transactions
  • How to recognize Passive Foreign Investment Companies (PFICs)
  • Issues raised by a global workforce

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.

Day One: 9:00 a.m. - 5:00 p.m.

Morning Session: 9:00 a.m. - 12:00 p.m.

9:00 Introduction and Opening Remarks

Linda E. Carlisle, John L. Harrington, Kristeen R. Witt

NEW SESSION
9:15 Outbound Investments

  • Description of common structures and their U.S. tax effects
  • Classification of U.S. and foreign entities for U.S. tax purposes
  • Implication of residency and effect of tax treatises
  • Blockers and why are they used
  • Sourcing issues
  • Inversions

John D. Bates, Sean W. Mullaney, Kristeen R. Witt

10:30 Networking Break

10:45 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 and reporting requirements
  • Treatment of distributions from CFCs
  • Possible changes

Rocco V. Femia, Brian H. Jenn, Phyllis E. Marcus

12:00 Lunch

Afternoon Session: 1:00 p.m. - 5:00 p.m.

1:00 Outbound M&A

  • Outbound Section 351 exchanges and reorganizations
  • Imputed royalties on outbound transfers of intangibles
  • Outbound spin-offs and liquidations
  • Foreign-to-foreign reorganizations and liquidations and their effect on tax attributes, such as deficits and foreign taxes
  • Reporting requirements arising from such transactions

Corey M. Goodman, Douglas L. Poms, Michael L. Schultz, Andrea Sharetta

2:15 Passive Foreign Investment Companies (PFICs)

  • How to recognize a PFIC
  • Avoiding PFIC status
  • The three PFIC taxation regimes
  • Making PFIC elections
  • PFIC reporting rules

Ethan A. Atticks, Kimberly S. Blanchard, Douglas L. Poms

3:30 Networking Break

3:45 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

Martin J. Collins, Douglas L. Poms, Carol P. Tello

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.

Morning Session: 9:00 a.m. - 1:00 p.m.

9:00 Inbound Investments

  • Description of common structures and their U.S. tax effects
  • Blockers and why are they used
  • Foreign Investment in Real Property Tax Act (FIRPTA) background, definitions, and implications
  • Withholding requirements, including withholding tax reductions provided by tax treaty
  • Branch profits tax rules

Guy A. Bracuti, William J. Corcoran, Brian H. Jenn

NEW SESSION
10:15 Foreign Bank and Financial Accounts (FBAR) and Other Reports Required by the IRS

  • Tax reporting requirements for owners of foreign entities and investments, including specified foreign assets and foreign trust reporting
  • Tax reporting requirements for payors, payees, and intermediaries
  • Tax reporting requirements for foreign-owned U.S. entities
  • FBAR requirements
  • Problems that arise when forms are not timely filed

Jeremy M. Naylor, Michael H. Plowgian

11:30 Networking Break

11:45 Cross-Border Financial Transactions

  • Determining functional currency
  • Branch transactions
  • Treatment of foreign currency transactions
  • Currency hedging and integration
  • Treatment of payments with respect to swaps, dividends and interest
  • Proposed legislative and regulatory changes

Douglas E. Chestnut, Brian H. Jenn, Mark H. Price

1:00 Lunch

Afternoon Session: 2:15 p.m. - 5:00 p.m.

2:15 Transfer Pricing

  • Section 482 and the arm’s length principle
  • Transfer pricing methods and their use
  • Special considerations for services, intangibles and cost-sharing agreements
  • Documentation, advance pricing agreements, and mutual agreement procedures
  • Proposed legislative and regulatory changes

Brian H. Jenn, Neal M. Kochman, Craig A. Sharon

3:30 Networking Break

NEW SESSION

3:45 Mobile Employees

  • U.S. tax rules applicable to U.S. individuals who work outside the United States, including the section 911 exclusion and sourcing rules
  • U.S. and foreign tax consequences to U.S. employers that have employees outside the United States
  • U.S. tax consequences to non-U.S. individuals who work in the United States
  • U.S. tax consequences to foreign employers that have employees in the United States
  • Importance of tax treaties
  • Reporting requirements

Mary B. Hevener, Patrycja Kowalska, Christie R. Sena

5:00 Adjourn

Co-Chair(s)
Linda E. Carlisle ~ Miller & Chevalier Chartered
John L. Harrington ~ Dentons US LLP
Kristeen R. Witt ~ Legislation Counsel, Joint Committee on Taxation
Speaker(s)
John D. Bates ~ Baker & Hostetler LLP
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Guy A. Bracuti ~ KPMG LLP
William J. Corcoran ~ Osler, Hoskin & Harcourt LLP
Rocco V. Femia ~ Miller & Chevalier Chartered
Corey M. Goodman ~ Cleary Gottlieb Steen & Hamilton LLP
Mary B. Hevener ~ Morgan, Lewis & Bockius LLP
Brian H. Jenn ~ Attorney Advisor (Tax Policy), U.S. Department of the Treasury
Neal M. Kochman ~ Caplin & Drysdale
Patrycja Kowalska ~ McGladrey LLP
Jeremy M. Naylor ~ Cooley LLP
Douglas L. Poms ~ Senior Counsel, Office of International Tax Counsel, U.S. Department of the Treasury
Mark H. Price ~ KPMG LLP
Michael L. Schultz ~ Bingham McCutchen LLP
Christie R. Sena ~ Deloitte Tax LLP
Andrea Sharetta ~ Dentons US LLP
Carol P. Tello ~ Sutherland Asbill & Brennan LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute

San Francisco Seminar Location

PLI California Center, 685 Market Street, San Francisco, California 94105. (415) 498-2800

San Francisco Hotel Accommodations

The Palace Hotel, 2 New Montgomery Street, San Francisco, California 94105. Call (800) 917-7456 seven days a week from 6:00 am to 12:00 am (PDT) and mention you are attending this program at Practising Law Institute to receive the preferred rate. For online reservations, go to www.sfpalace.com/pli to receive the preferred rate.

Westin San Francisco Market Street, 50 Third Street, San Francisco, CA 94103
Reservations can be made by calling 415-974-6400.  Ask for the corporate reservation coordinator and reference 287179.  You can also book online at westin.com/marketstreet and enter the above number.

Due to high demand we recommend reserving hotel rooms as early as possible.

PLI seminars qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state.

Please check the Credit Information box to the right of each product description for credit information specific to your state.

Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please Note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. PLI programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

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.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

This is a webcast of the live San Francisco 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.

This year’s program will be led by international tax experts and feature a substantially revised schedule including new sessions on outbound investments, IRS reporting requirements and mobile employees. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the U.S. tax rules address the issues raised. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities.

What you will learn

  • The impact of Subpart F on global businesses
  • What blockers are and why they are used for outbound and inbound investments
  • The background, purpose and history of foreign tax credits
  • The mechanics and significance of tax treaties
  • Transfer pricing principles and their use in transfer of goods, services and intangibles
  • Reporting and withholding requirements in international transactions
  • How to recognize Passive Foreign Investment Companies (PFICs)
  • Issues raised by a global workforce

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 P.D.T.

Day One: 9:00 a.m. - 5:00 p.m.  (P.D.T.)

Morning Session: 9:00 a.m. - 12:00 p.m.  (P.D.T.)

9:00 Introduction and Opening Remarks

Linda E. Carlisle, John L. Harrington, Kristeen R. Witt

NEW SESSION
9:15 Outbound Investments

  • Description of common structures and their U.S. tax effects
  • Classification of U.S. and foreign entities for U.S. tax purposes
  • Implication of residency and effect of tax treatises
  • Blockers and why are they used
  • Sourcing issues
  • Inversions

John D. Bates, Sean W. Mullaney, Kristeen R. Witt

10:30 Networking Break

10:45 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 and reporting requirements
  • Treatment of distributions from CFCs
  • Possible changes

Rocco V. Femia, Brian H. Jenn, Phyllis E. Marcus

12:00 Lunch

Afternoon Session: 1:00 p.m. - 5:00 p.m.  (P.D.T.)

1:00 Outbound M&A

  • Outbound Section 351 exchanges and reorganizations
  • Imputed royalties on outbound transfers of intangibles
  • Outbound spin-offs and liquidations
  • Foreign-to-foreign reorganizations and liquidations and their effect on tax attributes, such as deficits and foreign taxes
  • Reporting requirements arising from such transactions

Corey M. Goodman, Douglas L. Poms, Michael L. Schultz, Andrea Sharetta

2:15 Passive Foreign Investment Companies (PFICs)

  • How to recognize a PFIC
  • Avoiding PFIC status
  • The three PFIC taxation regimes
  • Making PFIC elections
  • PFIC reporting rules

Ethan A. Atticks, Kimberly S. Blanchard, Douglas L. Poms

3:30 Networking Break

3:45 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

Martin J. Collins, Carol P. Tello

5:00 Adjourn

Day Two: 9:00 a.m. - 5:00 p.m.  (P.D.T.)

Morning Session: 9:00 a.m. - 1:00 p.m.  (P.D.T.)

9:00 Inbound Investments

  • Description of common structures and their U.S. tax effects
  • Blockers and why are they used
  • Foreign Investment in Real Property Tax Act (FIRPTA) background, definitions, and implications
  • Withholding requirements, including withholding tax reductions provided by tax treaty
  • Branch profits tax rules

Guy A. Bracuti, William J. Corcoran, Brian H. Jenn

NEW SESSION
10:15 Foreign Bank and Financial Accounts (FBAR) and Other Reports Required by the IRS

  • Tax reporting requirements for owners of foreign entities and investments, including specified foreign assets and foreign trust reporting
  • Tax reporting requirements for payors, payees, and intermediaries
  • Tax reporting requirements for foreign-owned U.S. entities
  • FBAR requirements
  • Problems that arise when forms are not timely filed

Jeremy M. Naylor, Michael H. Plowgian

11:30 Networking Break

11:45 Cross-Border Financial Transactions

  • Determining functional currency
  • Branch transactions
  • Treatment of foreign currency transactions
  • Currency hedging and integration
  • Treatment of payments with respect to swaps, dividends and interest
  • Proposed legislative and regulatory changes

Douglas E. Chestnut, Brian H. Jenn, Mark H. Price

1:00 Lunch

Afternoon Session: 2:15 p.m. - 5:00 p.m.  (P.D.T.)

2:15 Transfer Pricing

  • Section 482 and the arm’s length principle
  • Transfer pricing methods and their use
  • Special considerations for services, intangibles and cost-sharing agreements
  • Documentation, advance pricing agreements, and mutual agreement procedures
  • Proposed legislative and regulatory changes

Brian H. Jenn, Neal M. Kochman, Craig A. Sharon

3:30 Networking Break

NEW SESSION

3:45 Mobile Employees

  • U.S. tax rules applicable to U.S. individuals who work outside the United States, including the section 911 exclusion and sourcing rules
  • U.S. and foreign tax consequences to U.S. employers that have employees outside the United States
  • U.S. tax consequences to non-U.S. individuals who work in the United States
  • U.S. tax consequences to foreign employers that have employees in the United States
  • Importance of tax treaties
  • Reporting requirements

Mary B. Hevener, Patrycja Kowalska, Christie R. Sena

5:00 Adjourn

Co-Chair(s)
Linda E. Carlisle ~ Miller & Chevalier Chartered
John L. Harrington ~ Dentons US LLP
Kristeen R. Witt ~ Legislation Counsel, Joint Committee on Taxation
Speaker(s)
John D. Bates ~ Baker & Hostetler LLP
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Guy A. Bracuti ~ KPMG LLP
William J. Corcoran ~ Osler, Hoskin & Harcourt LLP
Rocco V. Femia ~ Miller & Chevalier Chartered
Corey M. Goodman ~ Cleary Gottlieb Steen & Hamilton LLP
Mary B. Hevener ~ Morgan, Lewis & Bockius LLP
Brian H. Jenn ~ Attorney Advisor (Tax Policy), U.S. Department of the Treasury
Neal M. Kochman ~ Caplin & Drysdale
Patrycja Kowalska ~ McGladrey LLP
Jeremy M. Naylor ~ Cooley LLP
Douglas L. Poms ~ Senior Counsel, Office of International Tax Counsel, U.S. Department of the Treasury
Mark H. Price ~ KPMG LLP
Michael L. Schultz ~ Bingham McCutchen LLP
Christie R. Sena ~ Deloitte Tax LLP
Andrea Sharetta ~ Dentons US LLP
Carol P. Tello ~ Sutherland Asbill & Brennan LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute
PLI makes every effort to accredit its Live Webcasts. Please check the Credit Information box to the right of each product description for credit 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, Indiana1, Iowa*, Kansas*, Kentucky*, Louisiana, Maine*, Minnesota, Mississippi, Missouri, Montana, Nebraska, North Carolina, North Dakota, New Hampshire*, New Jersey, New Mexico, Nevada, New York2, Ohio3, Oklahoma, Oregon*, Pennsylvania4, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia5, 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.

Related Items

On-Demand  On-Demand Programs

International Tax Issues 2014 Feb. 13, 2014
Basics of International Taxation 2013 (San Francisco) Oct. 8, 2013

Handbook  Course Handbook Archive

Basics of International Taxation 2015  
International Tax Issues 2015  
International Tax Issues 2014  
Basics of International Taxation 2014 Kristeen R. Witt,
Linda E. Carlisle,
John L. Harrington,
 
International Tax Issues 2014 Michael A. DiFronzo, PricewaterhouseCoopers LLP
 
International Tax Issues 2013 Chicago Lowell D. Yoder, McDermott Will & Emery LLP
James P. Fuller, Fenwick & West LLP
Paul W. Oosterhuis, Skadden, Arps, Slate, Meagher & Flom LLP
Robert B. Stack, U.S. Department of the Treasury
Eric Solomon, EY
Manal S. Corwin, KPMG LLP
T. Timothy Tuerff, Deloitte Tax LLP
Michael A. DiFronzo, PwC
David A. Waimon, EY
Nicholas J. DeNovio, Latham & Watkins LLP
John D. McDonald, Baker & McKenzie LLP
Adam S. Halpern, Fenwick & West LLP
Rodney J. Lawrence, KPMG LLP
Steven M. Surdell, EY
Thomas Kittle-Kamp, Mayer Brown LLP
Damon M. Lyon, McDermott Will & Emery LLP
Thomas M. Zollo, KPMG LLP
William S. Dixon, Citigroup Global Markets Inc.
Rocco V. Femia, Miller & Chevalier Chartered
 
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