Seminar  Seminar

International Tax Issues 2014


Select a Location:

Co-Sponsored by Pennsylvania Bar Institute

Attendees in Pennsylvania will be viewing the live broadcast at the Pennsylvania Bar Institute's CLE Conference Center, Wanamaker Building, 10th floor, Philadelphia (Juniper St. entrance, between 13th & Broad Sts., opposite City Hall). You will have the opportunity to submit questions and will receive the printed Course Handbook.

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.

Morning Session: 9:00 a.m. - 12:45 p.m.

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.

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

Chairperson(s)
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Joseph M. Calianno ~ Grant Thornton LLP
Nicholas J. DeNovio ~ Latham & Watkins LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Rocco V. Femia ~ Miller & Chevalier Chartered
Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
Damon M. Lyon ~ McDermott Will & Emery LLP
Kimberly T. Majure ~ KPMG LLP
John D. McDonald ~ Baker & McKenzie LLP
Oren Penn ~ PwC
Gretchen T. Sierra ~ Deloitte Tax LLP
Dirk J.J. Suringa ~ Covington & Burling LLP
T. Timothy Tuerff ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute

Philadelphia Groupcast Location

Pennsylvania Bar Institute, The CLE Conference Center, Wanamaker Building, 10th floor, Suite 1010, Center City Philadelphia (Juniper St. entrance, between 13th & Broad Sts., opposite City Hall). (800) 932-4637. Click here for directions.

Philadelphia Groupcast Hotel Accommodations

Below is a list of hotel accommodations suggested by the Pennsylvania Bar Institute:

Marriott Residence Inn

Ritz Carlton

Loews Philadelphia

Philadelphia Marriott Downtown

Hilton Garden Inn

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE 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.

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.

Morning Session: 9:00 a.m. - 12:45 p.m.

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.

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

Chairperson(s)
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Joseph M. Calianno ~ Grant Thornton LLP
Nicholas J. DeNovio ~ Latham & Watkins LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Rocco V. Femia ~ Miller & Chevalier Chartered
Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
Damon M. Lyon ~ McDermott Will & Emery LLP
Kimberly T. Majure ~ KPMG LLP
John D. McDonald ~ Baker & McKenzie LLP
Oren Penn ~ PwC
Gretchen T. Sierra ~ Deloitte Tax LLP
Dirk J.J. Suringa ~ Covington & Burling LLP
T. Timothy Tuerff ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute

New York City Seminar Location

PLI New York Center
, 1177 Avenue of the Americas, (2nd floor), entrance on 45th Street, New York, New York 10036. Message Center, program days only: (212) 824-5733.

New York City Hotel Accommodations

Crowne Plaza Times Square Manhattan, 1605 Broadway (at 48th Street), New York, NY 10019 (212) 977-4000. When calling, mention Practising Law Institute. You can also make reservations online to access PLI's rates.

The Muse, 130 West 46th Street, New York, NY 10036.  Please call reservations at 1-800-546-7866. When calling, please mention Practising Law Institute.  You can also book online at https://gc.synxis.com/rez.aspx?Hotel=26750&Chain=10179&promo=PRLW.

Millennium Broadway Hotel, 145 West 44th Street, New York, NY 10036. Please call reservations at 1-800-622-5569.  When calling, please mention Practising Law Institute.  You can also book online at https://gc.synxis.com/rez.aspx?Hotel=11533&Chain=5303&promo=PLAW.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE 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 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

Chairperson(s)
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Joseph M. Calianno ~ Grant Thornton LLP
Nicholas J. DeNovio ~ Latham & Watkins LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Rocco V. Femia ~ Miller & Chevalier Chartered
Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
Damon M. Lyon ~ McDermott Will & Emery LLP
Kimberly T. Majure ~ KPMG LLP
John D. McDonald ~ Baker & McKenzie LLP
Oren Penn ~ PwC
Gretchen T. Sierra ~ Deloitte Tax LLP
Dirk J.J. Suringa ~ Covington & Burling LLP
T. Timothy Tuerff ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute
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, 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.

Co-Sponsored by Pennsylvania Bar Institute

Attendees in Pennsylvania will be viewing the live broadcast at the the Pennsylvania Bar Institute's Professional Development Conference Center, Heinz 57 Center, 339 Sixth Avenue, 7th Floor, Pittsburgh, Pennsylvania 15222-2517. You will have the opportunity to submit questions and will receive the printed Course Handbook.

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.

Morning Session: 9:00 a.m. - 12:45 p.m.

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.

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

Chairperson(s)
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Joseph M. Calianno ~ Grant Thornton LLP
Nicholas J. DeNovio ~ Latham & Watkins LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Rocco V. Femia ~ Miller & Chevalier Chartered
Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
Damon M. Lyon ~ McDermott Will & Emery LLP
Kimberly T. Majure ~ KPMG LLP
John D. McDonald ~ Baker & McKenzie LLP
Oren Penn ~ PwC
Gretchen T. Sierra ~ Deloitte Tax LLP
Dirk J.J. Suringa ~ Covington & Burling LLP
T. Timothy Tuerff ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute

Pittsburgh Groupcast Location

Pennsylvania Bar Institute, Professional Development Conference Center, 339 Sixth Avenue, Suite 760, Pittsburgh, Pennsylvania 15222-2517. (412) 802-2300. Click here for directions.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE 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.

Co-Sponsored by Pennsylvania Bar Institute

Attendees in Pennsylvania will be viewing the live broadcast at the Pennsylvania Bar Institute, 5080 Ritter Rd., Mechanicsburg, PA 17055. You will have the opportunity to submit questions and will receive the printed Course Handbook.

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.

Morning Session: 9:00 a.m. - 12:45 p.m.

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.

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

Chairperson(s)
Speaker(s)
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Joseph M. Calianno ~ Grant Thornton LLP
Nicholas J. DeNovio ~ Latham & Watkins LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Rocco V. Femia ~ Miller & Chevalier Chartered
Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
Damon M. Lyon ~ McDermott Will & Emery LLP
Kimberly T. Majure ~ KPMG LLP
John D. McDonald ~ Baker & McKenzie LLP
Oren Penn ~ PwC
Gretchen T. Sierra ~ Deloitte Tax LLP
Dirk J.J. Suringa ~ Covington & Burling LLP
T. Timothy Tuerff ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute

Mechanicsburg Groupcast Location

Pennsylvania Bar Institute, 5080 Ritter Rd., Mechanicsburg PA 17055, (800) 932-4637. Click here for directions.

Mechanicsburg Groupcast Hotel Accommodations

Below is a list of hotel accommodations suggested by the Pennsylvania Bar Institute:

Hampton Inn Harrisburg-West, 4950 Ritter Road, Mechanicsburg, Pennsylvania, USA 17055. Tel: 717-691-1300. Fax: 717-691-9692.

Homewood Suites by Hilton® Harrisburg-West Hershey Area, 5001 Ritter Road, Mechanicsburg, Pennsylvania, United States 17055. Tel: 1-717-697-4900. Fax: 1-717-697-9101.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE 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.

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.

Program Schedule To Come
Chairperson(s)
Lowell D. Yoder ~ McDermott Will & Emery LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute
Chicago Seminar Location

University of Chicago Gleacher Center, 450 N. Cityfront Plaza Drive, Chicago, Illinois 60611. (312) 464-8787.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE 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.

Related Items

On-Demand  On-Demand Programs

Basics of International Taxation 2013 Oct. 8, 2013
Basics of International Taxation 2013 Aug. 7, 2013
International Tax Issues 2013 Feb. 14, 2013

Handbook  Course Handbook Archive

Basics of International Taxation 2014  
International Tax Issues 2014  
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
Thomas M. Zollo, KPMG 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
William S. Dixon, Citigroup Global Markets Inc.
Rocco V. Femia, Miller & Chevalier Chartered
 
Basics of International Taxation 2013 Linda E. Carlisle, White & Case LLP
Ethan A. Atticks, PwC
Douglas E. Chestnut, EY
Phyllis E. Marcus, PwC
J. David Varley, Internal Revenue Service
Kristeen R. Witt, Joint Committee on Taxation
Layla J. Aksakal, Miller & Chevalier Chartered
Natalie Hodapp, Internal Revenue Service
Melody H. Leung, EY
John Anthony Coughlan, U.S. Senate Committee on Finance
Peter C. Rock, Internal Revenue Service
Erica L. Gut, PwC
Kimberly S. Blanchard, Weil, Gotshal & Manges LLP
Daniel P. Messing, EY
Andrew P. Solomon, Sullivan & Cromwell LLP
Carol P. Tello, Sutherland Asbill & Brennan LLP
William J. Corcoran, Osler, Hoskin & Harcourt LLP
Martin J. Collins, PwC
Chris Bowers, Bingham McCutchen LLP
Jeremy M. Naylor, Cooley LLP
Michael L. Schultz, Bingham McCutchen LLP
Mark H. Price, KPMG LLP
Howard A. Wiener, KPMG LLP
Eileen Marshall, Wilson Sonsini Goodrich & Rosati, P.C.
Jefferson P. Vanderwolk, EY
Rachel D. Kleinberg, Davis Polk & Wardwell LLP
Steven C. Wrappe, EY
Guy A. Bracuti, KPMG LLP
Michael H. Plowgian, KPMG LLP
Brion D. Graber, Scribner, Hall & Thompson, LLP
John L. Harrington, Dentons US LLP
Elena V. Romanova, Citigroup
Catherine G. Schultz, National Foreign Trade Council (NFTC)
Arlene S. Fitzpatrick, U.S. Department of the Treasury
Jonathan R. Zelnik, KPMG LLP
Gregory R. Walker, EY
John M. Grimes, JPMorgan Chase & Co.
Richard G. Larkins, EY
Rocco V. Femia, Miller & Chevalier Chartered
Kevin M. Levingston, PwC
 
International Tax Issues 2013 Michael A. DiFronzo, PwC
 
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