On-Demand   On-Demand Web Programs

International Tax Issues 2019

Released on: Feb. 12, 2019
Running Time: 06:31:01

As the world’s economies grow increasingly integrated through trade, acquisitions and joint ventures, U.S. international tax laws impact a greater percentage of businesses and transactions. These international tax rules affect not only large U.S. and non-U.S. based multinationals, but also increasingly affect mid-sized and smaller organizations and investors, financing transactions, mergers and acquisitions, and other commercial activity.  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 in light of the 2017 Tax Act.  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 non-U.S. based organizations and investors.
 
Topics Include

  • Transfer pricing developments and transfer pricing’s role in new GILTI and FDII provisions
  • The impact of OECD developments on BEPS, treaty developments and the new BEAT and hybrid provisions included in the 2017 Tax Act
  • Cross-border merger and acquisition issues, techniques and developments, including new Sections 245A, 367(a) and 965
  • Changes to the anti-deferral rules, foreign tax credits and FDII
  • Dealing with international joint ventures, revisiting fund structures and the new paradigm shift for the partnership form 
Lecture Topics [Total time 06:31:01]

Segments with an asterisk (*) are available only with the purchase of the entire program.

  • Opening Remarks* [00:01:29]
    Michael A. DiFronzo
  • Inbound Planning and Developments [01:11:07]
    Peter A. Glicklich, Oren Penn
  • Developments on Transfer Pricing [00:59:15]
    Rocco V. Femia, Thomas M. Zollo, Thomas A. Vidano
  • Cross-Border M&A Planning and Developments [01:32:09]
    Ronald A. Dabrowski, Diana S. Doyle, Shane M. McCarrick, Moshe Spinowitz
  • Foreign Tax Credits and Subpart F Planning and Developments [01:31:20]
    Stephen R.A. Bates, David J. Sotos, Christopher Trump
  • Cross-Border Partnership Planning and Developments [01:15:39]
    Ari Berk, Peter H. Blessing, Joseph M. Calianno, Karen Lohnes

The purchase price of this Web Program includes the following articles from the Course Handbook available online:

  • COMPLETE COURSE HANDBOOK
  • The Impact of U.S. Tax Reform on Canada-U.S. M&A (November 6, 2018)
    Peter A. Glicklich
  • KPMG Comment—Comments on Discussion Draft: Revised Guidance on Profit Splits (September 15, 2017)
    Thomas M. Zollo
  • KPMG Comment—Comments on Discussion Draft: Additional Guidance on Attribution of Profits to Permanent Establishments (September 2017)
    Thomas M. Zollo
  • Latham & Watkins Client Alert Commentary: New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate Borrowings, No. 2405 (November 5, 2018)
    Diana S. Doyle
  • Latham & Watkins Client Alert Commentary: Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform, No. 2355 (July 26, 2018)
    Diana S. Doyle
  • Latham & Watkins Client Alert Commentary: Withholding Guidance Issued on Sale of Interests in a Partnership with US Assets, No. 2298 (April 5, 2018)
    Diana S. Doyle
  • Latham & Watkins White Paper, US Tax Reform: Key Business Impacts, Illustrated with Charts and Transactional Diagrams, No. 2266 (January 10, 2018)
    Diana S. Doyle
  • PwC Knowledge & Insight: IRS Issues Proposed Rules on ‘GILTI’ under Section 951A (September 28, 2018)
    Timothy J. Lohnes, Michael A. DiFronzo
  • PwC Knowledge & Insight: Treasury Issues Proposed Rules Related to Foreign Tax Credits (December 14, 2018)
    Elizabeth Nelson, David J. Sotos, Carl Dubert
  • PwC Knowledge & Insight: Proposed Regulations Would Reduce Section 956 Amounts for Domestic Corporations (November 2, 2018)
    Rebecca E. Lee, Michael A. DiFronzo, John Evans Harrell
  • PwC Knowledge & Insight: Treasury Releases Notice 2019-01—Previously Taxed Earnings and Profits Accounts (December 14, 2018)
    David J. Sotos, Marco Fiaccadori, Elizabeth A. Hall
  • PwC Knowledge & Insight: Preliminary Highlights of the Proposed BEAT Regulations (December 14, 2018)
    Michael A. DiFronzo, Marco Fiaccadori, Julie Allen
  • New York State Bar Association, Tax Section, Report No. 1394 on the GILTI Provisions of the Code (May 4, 2018)
  • Congressional Research Service, Issues in International Corporate Taxation: The 2017 Revision (P.L. 115-97) (May 1, 2018)

Presentation Material

  • Inbound Planning & Developments
    Peter A. Glicklich, Oren Penn, John D. Bates
  • Transfer Pricing Developments and Planning
    Rocco V. Femia, Thomas A. Vidano, Thomas M. Zollo
  • Cross-Border M&A Planning & Developments
    Ronald A. Dabrowski, Diana S. Doyle, Moshe Spinowitz
  • Foreign Tax Credits and Subpart F Planning and Developments
    Stephen R.A. Bates, David J. Sotos, Christopher Trump
  • Cross-Border Partnership Planning and Developments
    Ari Berk, Peter H. Blessing, Joseph M. Calianno, Karen Lohnes
Chairperson(s)
Speaker(s)
Ari Berk ~ Deloitte Tax LLP
Peter H. Blessing ~ KPMG LLP
Joseph M. Calianno ~ BDO USA, LLP
Diana S. Doyle ~ Latham & Watkins LLP
Rocco V. Femia ~ Miller & Chevalier Chartered
Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
Shane M. McCarrick ~ Senior Counsel, Office of the Associate Chief Counsel (International, Branch 4), Internal Revenue Service
Oren Penn ~ PwC
Moshe Spinowitz ~ Skadden, Arps, Slate, Meagher & Flom LLP
Christopher Trump ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
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PLI’s live and on-demand webcasts are single-user license products intended for an individual registrant only. Credit will be issued only to the individual registered.


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New York

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Newly Admitted Attorneys:  PLI’s transitional on-demand web programs can be used to fulfill the requirements for New York newly admitted attorneys. Only professional practice and law practice management credits may be earned via transitional on-demand web programs. Ethics and skills credits may not be earned via on-demand web programs.

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Rhode Island:  PLI’s on-demand web programs qualify as “video replay” credit. Attorneys are limited to 6 video replay credits per reporting period.

South Carolina:  PLI’s on-demand web programs qualify as “alternatively delivered” credit. Attorneys are limited to 6 credits of alternatively delivered programs per reporting period.

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Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 10 credits of self-study per reporting period.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s on-demand web programs qualify as “pre-recorded” credit. Attorneys are limited to 8 credits of pre-recorded programs per reporting period.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s on-demand web programs qualify as “online” credit. Attorneys are limited to 12 credits of online instruction per reporting period.

Wisconsin:  PLI’s on-demand web programs qualify as “repeated, on-demand” credit. Attorneys are limited to 15 credits of repeated, on-demand programs per reporting period. No ethics credits can be earned via on-demand web programs.

Wyoming:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 6 credits of self-study per reporting period.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s on-demand web programs are not eligible for CPD-BC credit unless viewed with at least one other attorney or an articled student. In this case, the credit must be recorded as a “study group.”

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Quebec (CPD-QC):  PLI’s on-demand web programs can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s on-demand web programs are not approved for CPD-HK credit.

United Kingdom (CPD-UK):  PLI’s on-demand web programs can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s on-demand web programs may fulfill Australia’s CPD requirements. Credit limits for on-demand web programs vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

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Dubai (CLPD-DUBAI):  PLI’s on-demand web programs may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  Select on-demand web programs qualify as the “QAS Self-Study” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s on-demand web programs may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

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IAPP Continuing Privacy Credit (CPE):  PLI’s on-demand web programs may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s on-demand web programs may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s on-demand web programs qualify as "self-paced" credit. SHRM professionals are limited to 30 credits of self-paced programs per recertification period.

Compliance Certification Board (CCB):  PLI’s on-demand web programs qualify as “self-study” credit. Candidates are limited to 10 self-study credits per 12-month period, and certification holders are limited to 20 self-study credits per 2-year renewal period.

Certified Anti-Money Laundering Specialists Certification (CAMS):  PLI’s on-demand web programs are not approved for CAMS credit.

New York State Social Worker Continuing Education (SW CPE):  PLI’s on-demand web programs are not approved for SW CPE credit.

American Bankers Association Professional Certification (ABA):  PLI’s on-demand web programs may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s on-demand web programs are not approved for CFP credit.

 

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