This is a webcast of the live New York session.Why you should attend
As the world’s economies grow increasingly integrated, the international tax laws of the U.S. impact a greater percentage of businesses and transactions. These international tax rules affect not only large U.S. and foreign-based multinationals, but also increasingly affect mid-sized and smaller firms, financing transactions, mergers and acquisitions, and other commercial activity. As a result, a working knowledge of these international tax rules is of paramount importance to a wide variety of tax professionals.
At this year’s program we will assemble some of the world’s leading experts and senior government officials to discuss the complex rules of U.S. international taxation. We will focus upon both operational and transactional implications of these rules, and will describe the application of the rules to both U.S. and foreign-based entities.
What you will learn
- Update your knowledge of current developments facing non-U.S. persons
- Understand the intricacies of managing offshore cash and efficient utilization of foreign cash
- Identify cross-border merger and acquisition issues, techniques and developments
- Get an update on new foreign tax credit rules implementing the 2010 legislation (including splitter) and Subpart F developments
- Examine recent developments in transfer pricing audits and planning
- Work through all of the above against the backdrop of proposed international tax reform legislation, identifying the key concepts and predicting the future
Who should attend
Law firm and accounting firm professionals who advise clients on structuring cross border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and internal planning, in FIN 48 determinations and in IRS audits and appeals of international issues; and government attorneys who want to stay on top of what’s happening in the international tax arena.
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.S.T.
Morning Session: 9:00 a.m. - 12:45 p.m. (E.S.T.)
9:00 Introduction and Opening Remarks
Michael A. DiFronzo
9:15 Inbound Issues and Planning
- FATCA
- FIRPTA
- Debt/equity developments
- Treaty developments and permanent establishment considerations
- Characterization, source and withholding
Kimberly S. Blanchard, Peter A. Glicklich, Oren S. Penn, Danielle E. Rolfes (invited)
10:15 Managing Offshore Cash
- Cash pool arrangements
- Short term loans to U.S. affiliates
- Advance payments - inventory, services and royalties
- Return of basis distributions
- Section 304 - accessing high taxed earnings and basis
- Legislative proposals targeting the monetization of assets
Joseph M. Calianno, William S. Dixon, Rebecca E. Lee, Kimberly T. Majure
11:15 Networking Break
11:30 Cross Border M&A Planning
- Acquisitions of foreign targets
- Acquisition of U.S. targets with foreign subsidiaries
- Foreign multinationals acquiring U.S. targets
- Section 367 developments, including 367(a)(5) regulations
- Section 7874 developments
- Maximizing use of foreign cash to fund acquisitions
Nicholas J. DeNovio, Hal Hicks, Steven M. Surdell, T. Timothy Tuerff
12:45 Lunch
Afternoon Session: 1:45 p.m. - 5:00 p.m. (E.S.T.)
1:45 Foreign Tax Credit & Subpart F Developments
- Section 901 technical taxpayer regulations
- Section 909 splitter regulations
- Section 901(m) covered asset acquisitions
- Section 960(c) anti-hopscotch rule
- Compulsory tax issues
- Subpart F sales & services income
- Planning for potential territorial tax system
Damon M. Lyon, John D. McDonald, Gretchen T. Sierra, Dirk J.J. Suringa
3:30 Networking Break
3:45 Recent Developments on Transfer Pricing
- Government update on transfer pricing practice
- Consolidation of APA and competent authority into the APMA program
- Impact of IRS administrative changes on transfer pricing exams, APAs and Competent Authority cases
- IP planning
- When is cost sharing still viable planning?
Rocco V. Femia, Samuel M. Maruca (invited), Steven C. Wrappe, Thomas M. Zollo
5:00 Adjourn
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.