Tax

International

Recorded on: Dec. 21, 2011

AMY TAUB: Thank you. Greetings. My name is Amy Taub and I am a program attorney with PLI. I would like to welcome you to today's briefing, Computing Tax in the Cloud, State and International Implications. Before we begin, I have some administrative announcements. This briefing will be one hour in length. Please feel free to send questions at any time during the briefing. Please remember that you have access to materials for this briefing via the course ...

Course Handbook from the program International Tax Issues 2012, held February, 2012.

Course Handbook from the program Real Estate Tax Forum (14th Annual), held March, 2012.

Recorded on: Mar. 22, 2012

SANFORD C. PRESANT: OK. Our next speakers are Michael Hirschfeld and Gino Bianchini. Michael Hirschfeld, former partner of mine at-- MICHAEL HIRSCHFELD: [INAUDIBLE]. SANFORD C. PRESANT: Where was it? Where was it, OK? Tell me. OK. Oh, Gino. Perfect. Wonderful. OK. SPEAKER 1: --and Presant. SANFORD C. PRESANT: He's a partner in the New York office of Dechert LLP. He specializes in international corporate workout partnership matters. He's Vice President ...

From the program: International Estate & Tax Planning 2012: Planning for the International Private Client

Released on: Jun. 5, 2012

DVD's from the program International Estate & Tax Planning 2012: Planning for the International Private Client, held April, 2012.

Recorded on: May. 16, 2012

Taken from the briefing Transfer Pricing: Managing Risks in Light of New IRS Enforcement Initiatives recorded May, 2012. The phenomenon of increasingly global business enterprises with valuable intangible property exposes companies to transfer pricing enforcement by different countries around the world.  Government taxing authorities are becoming more aggressive in enforcing transfer pricing rules as they move to protect their tax bases.  ...

From the program: Basics of International Taxation 2012

Recorded on: Jul. 25, 2012

Taken from the Web Program Basics of International Taxation recorded July, 2012 in New York. Lecture Topics  [01:14:43] M&A and Section 367  [01:14:43] 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 ...

Released on: Nov. 1, 2012

Taken from the briefing FATCA: The Deadline Looms... Will You Be Ready? recorded October, 2012. In the wake of the massive criminal tax prosecutions of UBS and other foreign firms by the Department of Justice in the late 2000s, Congress enacted FATCA to combat tax evasion by U.S. persons and to deter the facilitation of tax evasion by foreign financial institutions (“FFIs”).  To achieve these goals, FATCA requires that foreign ...

From the program: International Tax Issues 2013

Recorded on: Feb. 4, 2013

Taken from the Web Program International Tax Issues 2013 recorded January, 2013 in New York. Lecture Topics  [01:15:16] Recent Developments on Transfer Pricing  [01:15:16] Realignment from LMSB to LB&I and the creation of a 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  ...

Published: April 2013

From the program: International Estate & Tax Planning 2013

Released on: May. 7, 2013

Individuals with connections to more than one country - international private clients - need sophisticated succession and tax planning advisors to help them navigate a complex and sometimes treacherous legal, tax and regulatory environment. These clients include U.S. persons with assets or beneficiaries outside the United States, as well as non-U.S. persons with U.S. connections. Their advisors must view a client’s specific circumstances ...

Course Handbook from the program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2013, held April, 2013.

• Jul. 17, 2013