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 US 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
- Explore recently proposed International Tax Reform legislation, identifying the key concepts and predicting the future
- 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 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.
Morning Session: 9:00 a.m. - 12:30 p.m.
9:00 Introduction and Opening Remarks
Michael A. DiFronzo
9:15 Inbound Issues and Planning
- Debt/equity developments
- Treaty developments and permanent establishment considerations
- Characterization, source and withholding
Kimberly S. Blanchard, Jesse F. Eggert, Peter A. Glicklich, Oren S. Penn
10:15 Managing Offshore Cash
- Cash pool arrangements
- Short term loans to U.S. affiliates
- Advance payments - inventory, services & royalties
- Return of basis distributions
- Section 304 - accessing high taxed earnings & basis
- Legislative proposals targeting the monetization of assets
William S. Dixon, L.G. “Chip” Harter, Kimberly T. Majure, Gregory R. Walker
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
- Section 7874 developments
- Maximizing use of foreign cash to fund acquisitions
Peter H. Blessing, Hal Hicks, T. Timothy Tuerff
Afternoon Session: 1:45 p.m. - 5:00 p.m.
1:45 Foreign Tax Credit & Subpart F Developments
- New section 901 technical taxpayer regulations
- New section 909 splitter regulations
- New section 901(m) covered asset acquisition regulations
- Section 960(c) anti-hopscotch rule
- Compulsory tax issues
- Subpart F sales & services income
- Planning for potential territorial tax system
James P. Fuller, John D. McDonald, Lowell D. Yoder
3:30 Networking Break
3:45 Recent Developments on Transfer Pricing
- 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
- IP planning
- Cost sharing regulations
David J. Canale, Rocco V. Femia, Samuel M. Maruca, Thomas M. Zollo
William S. Dixon
~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Jesse F. Eggert
~ Associate International Tax Counsel, Office of International Tax Counsel, U.S. Department of the Treasury
~ Skadden, Arps, Slate, Meagher & Flom LLP
Samuel M. Maruca
~ Director, Transfer Pricing Operations; Large Business & International Division (LB&I), Internal Revenue Service
New York City Seminar Location
PLI New York Center, 810 Seventh Avenue at 53rd Street (21st floor), New York, New York 10019. Message Center, program days only: (212) 824-5733.
New York City Hotel Accommodations
The New York Hilton & Towers
1335 Avenue of the Americas, New York, NY 10019. 1 block from PLI Center. Reservations 1-800-HILTONS or, 1-877-NYC-HILT. Please mention that you are booking a room under the Practising Law Institute Corporate rate and the Client File # is 0495741. You can also make reservations
online to access Practising Law Institute rates.
The Warwick New York Hotel, 65 West 54th Street New York, NY 10019. 1 block from PLI Center. Reservations 800-223-4099 or, hotel direct 212-247-2700. Please mention that you are booking a room under the Practising Law Institute Corporate rate. Reservations on line at www.warwickhotelny.com Click reservations in menu bar on left. Select desired dates. In 'Special Rates' drop down window select Corporate Rate. In 'Rate Code' enter PLIN. Click search and select desired room type and rate plan. Or, you may email reservation requests to: firstname.lastname@example.org
Sheraton New York Hotel & Towers
, 811 7th Avenue, New York, NY 10019, 1-800-325-3535 or (212) 581-1000. When calling, please mention Practising Law Institute and mention SET#311155. You may also book online
PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state 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.
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.