Seminar  Seminar

International Tax Issues 2016


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
• Survey the current landscape of International Tax Reform legislative proposals, identifying the key concepts and predicting the future
• Understand the new debt versus equity regulations and their practical applications
• Hear planning strategies for dealing with cross-border mergers and acquisitions, including the new inversion regulations
• Get an update on foreign tax credit regulations implementing the 2010 legislation (including splitter and covered asset acquisition structures) and Subpart F developments
• Examine recent developments in transfer pricing audits and planning

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.

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.

9:00 Introduction and Opening Remarks
Lowell D. Yoder

9:10 Cross Border M&A Tax Planning
• Acquisitions of foreign targets
• Acquisition of U.S. targets with foreign subsidiaries
• Foreign multinationals acquiring U.S. targets
• Section 367 developments
• Section 7874 developments (including the new regulations)
• Debt funded acquisitions and intercompany leverage (including new Section 385 regulations)
• Maximizing use of foreign cash to fund acquisitions
Nicholas J. DeNovio, John J. Merrick (Invited), Paul W. Oosterhuis, Steven M. Surdell

10:45 Networking Break

11:00 Foreign Tax Credit (FTC) & Subpart F Developments
• Section 901(m) covered asset acquisition rules
• FTC developments and issues
• Subpart F developments and issues
• International tax reform
• Implications of Proposed Section 385 Regulations in the FTC and Subpart F areas
Adam S. Halpern, Jose E. Murillo, Marjorie A. Rollinson (Invited), Gretchen T. Sierra

12:30 Lunch

Afternoon Session: 1:45 p.m. - 5:00 p.m.


1:45 Legislative Outlook - International Tax Reform
• Tax reform approaches -- territorial, hybrid, or worldwide current taxation?  Impact of integration?
• Impact on U.S. tax reform of BEPS implementation, foreign tax legislation, state aid and the new Section 385 regulations
• Thin cap and other proposals to restrict interest deductibility
• Redomestication limitations
• Predicting the future
Ronald A. Dabrowski, Pamela F. Olson, Danielle E. Rolfes (Invited), Eric Solomon

3:15 Networking Break

3:30 Recent Developments on Transfer Pricing

• Impact of IRS administrative changes on transfer pricing exams, APAs and Competent Authority cases, including recent experiences with IRS Transfer Pricing Practice
• Developments in cost-sharing, IP, and planning generally, including impact of case law and regulatory developments
• BEPS and transfer pricing, including selected international developments and updates
• New and revised regulations, including proposed country-by-country reporting regulations, changes to Section 482 aggregation rules, and the treatment of outbound transfers under Sections 367 and 721
Mark Horowitz, Clisson S. Rexford (Invited), Russell R. Young, Thomas M. Zollo

5:00 Adjourn



Chairperson(s)
Lowell D. Yoder ~ McDermott Will & Emery LLP
Speaker(s)
Nicholas J. DeNovio ~ Latham & Watkins LLP
Adam S. Halpern ~ Fenwick & West LLP
Mark Horowitz ~ McDermott Will & Emery LLP
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Paul W. Oosterhuis ~ Skadden, Arps, Slate, Meagher & Flom LLP
Marjorie A. Rollinson ~ Associate Chief Counsel (International), Internal Revenue Service
Gretchen T. Sierra ~ Deloitte Tax LLP
Russell R. Young ~ Baker & McKenzie LLP
Thomas M. Zollo ~ KPMG LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Program Attorney, Practising Law Institute

Chicago Seminar Location

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

Hotel Accommodation

Intercontinental Hotel Chicago, 505 N. Michigan Avenue, Chicago, IL 60611. (312) 944-4100.  A block of rooms has been reserved for this program.  Please call reservations at 1-800-628-2112 and mention the name of the program you are attending. 

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Related Items

On-Demand  On-Demand Programs

Basics of International Taxation 2015 (New York City) Aug. 5, 2015

Handbook  Course Handbook Archive

International Tax Issues 2016 Lowell D. Yoder, McDermott Will & Emery LLP
Marjorie A. Rollinson, Internal Revenue Service
Jose E. Murillo, EY
Paul W. Oosterhuis, Skadden, Arps, Slate, Meagher & Flom LLP
Eric Solomon, EY
Ronald A. Dabrowski, KPMG LLP
Gretchen T. Sierra, Deloitte Tax LLP
Pamela F. Olson, PwC
Nicholas J. DeNovio, Latham & Watkins LLP
John J. Merrick, Internal Revenue Service
Mark Horowitz, McDermott Will & Emery LLP
Adam S. Halpern, Fenwick & West LLP
Steven M. Surdell, EY
Russell R. Young, Baker & McKenzie LLP
Thomas M. Zollo, KPMG LLP
 
Basics of International Taxation 2016  
International Tax Issues 2016 Michael A DiFronzo, PwC
Michael A. DiFronzo, PwC
Oren Penn, PwC
David J. Canale, EY
Harrison J. Cohen, Deloitte LLP
Sean Hailey, EY
Peter H. Blessing, KPMG LLP
T. Timothy Tuerff, Deloitte Tax LLP
Paul M. Schmidt, Baker & Hostetler LLP
Nicholas J. DeNovio, Latham & Watkins LLP
Peter A. Glicklich, Davies Ward Phillips & Vineberg LLP
Jennifer H. Alexander, Deloitte Tax LLP
John J. Merrick, Internal Revenue Service
Dirk J.J. Suringa, Covington & Burling LLP
Karen Lohnes, PwC
Joseph M. Calianno, BDO USA, LLP
Thomas M. Zollo, KPMG LLP
Moshe Spinowitz, Skadden, Arps, Slate, Meagher & Flom LLP
Rocco V. Femia, Miller & Chevalier Chartered
 
International Tax Issues Chicago 2015 Lowell D Yoder, McDermott Will & Emery LLP
 
Basics of International Taxation 2015 Linda E Carlisle, Miller & Chevalier Chartered
John L Harrington, Dentons US LLP
 
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