On-Demand   On-Demand Web Programs

Basics of International Taxation 2017

Released on: Sep. 26, 2017
Running Time: 13:18:51

In a global business environment, transactions with customers and suppliers often transcend national borders and investment and activities are frequently cross-border as well.   A working knowledge of the U.S. international tax rules is, therefore, of paramount importance to a wide variety of tax and corporate professionals.

This year’s program will be led by international tax experts and focuses on specific types of outbound and inbound investment and activities, and their U.S. tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the U.S. tax rules address the issues raised. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities.

You will learn:

  • Study the impact of Subpart F on global businesses
  • Explore the background, purpose and history of foreign tax credits
  • Understand the mechanics and significance of tax treaties
  • Examine new Treasury guidance on transfer of intangible assets, and on foreign currency
  • Get an overview of the reporting and withholding requirements in international transactions
  • Learn to recognize Passive Foreign Investment Companies (PFICs)
  • Identify the issues raised by a global workforce

Corporate, law firm and accounting firm professionals that consider cross-border transactions and need a working knowledge of relevant U.S. international tax rules, and government attorneys who want to stay on top of what’s happening in the international tax arena will benefit from this program.

Lecture Topics [Total time 13:18:51]

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


  • Introduction and Opening Remarks* [00:03:52]
    Linda E. Carlisle, John L. Harrington
  • Overview of U.S. International Tax System [01:02:04]
    Linda E. Carlisle, John L. Harrington
  • Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) – Active Business Operations [01:15:59]
    Andrea Sharetta, Justin E. Jesse
  • Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) – Lending, Licensing and Portfolio Investments [01:01:50]
    Ethan A. Atticks, Corey M. Goodman
  • International Tax Reporting and Dealing with Noncompliance [00:59:30]
    Robert M. Temin, Josh O. Ungerman
  • Relieving and Avoiding Double Tax in an International Context [01:14:10]
    Carol P. Tello, Karen J. Cate, Matthew M. Chen
  • Outbound Transfers of Intangible Assets and Treatment of Foreign Currency [01:05:15]
    Jose E. Murillo, Philip B. Wright
  • Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments [01:31:10]
    John D. Bates, David L. Forst
  • Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Passive Investments & U.S. Withholding and Reporting [01:17:20]
    Jeremy M. Naylor, James S.H. Null
  • Transfer Pricing– Inbound and Outbound [01:16:21]
    Neal M. Kochman, Frank (Chip) W. Dunham III, Melody H. Leung
  • Cross-Border Services and Employment Tax Issues [01:15:10]
    Candace B. Ewell, Narendra Acharya
  • International Tax Aspects of Tax Reform [01:16:10]
    E. Ray Beeman, Janice A. Mays

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


  • COMPLETE COURSE HANDBOOK
  • Overview of U.S. International Tax System
    Linda E. Carlisle, John L. Harrington
  • US Persons Operating Outside the United States: Outbound Active Business Operations (April 2017)
    Andrea Sharetta
  • U.S. Persons Investing or Operating Outside of the United States (Outbound Investments)—Lending, Licensing, and Portfolio Investments
    Ethan A. Atticks, Corey M. Goodman
  • U.S. Persons Investing or Operating Outside of the United States (Outbound Investments)—Lending, Licensing, and Portfolio Investments (PowerPoint slides)
    Ethan A. Atticks, Corey M. Goodman
  • Tax Reporting and Dealing with Noncompliance
    Robert M. Temin
  • The IRS Reached the Expert Level in Offshore Matters: Tax Professionals Must Be Aware of the Remediation Options for Undisclosed Offshore Assets (May 1, 2017)
    Josh O. Ungerman
  • The IRS Reached the Expert Level in Offshore Matters: Tax Professionals Must Be Aware of the Remediation Options for Undisclosed Offshore Assets (PowerPoint slides)
    Josh O. Ungerman
  • An Introduction to the Foreign Tax Credit (April 2017)
    Carol P. Tello
  • Overview of U.S. Tax Treaties (April 28, 2017)
    John L. Harrington
  • An Introduction to the Foreign Tax Credit (PowerPoint slides)
    Ninee S. Dewar, Carol P. Tello
  • Foreign Currency Transactions and Foreign Currency Translation Gain and Loss Section 987 Foreign Branch Currency Regulations (May 2017)
    Philip B. Wright
  • Sullivan & Cromwell Client Memo: IRS Releases Chief Counsel Advice Memorandum 201501013, Treating a Foreign Fund with No Employees as Engaged in a Trade or Business in the United States Through the Lending and Underwriting Activities of the Fund’s Manager, and Clarifying Trading Safe Harbors (January 26, 2015)
    S. Eric Wang
  • Cooley Alert: New US Debt-Equity Rules Target Earnings Stripping (October 20, 2016)
    Jeremy M. Naylor
  • Transfer Pricing and Section 482: An Overview of U.S. Transfer Pricing Rules
    Steven C. Wrappe, Neal M. Kochman
  • Transfer Pricing (PowerPoint slides)
    Steven C. Wrappe, Neal M. Kochman
  • Miller & Chevalier Memorandum: Cross-Border Services and Employment Tax Issues (April 29, 2016)
    Michael M. Lloyd, Candace B. Ewell
  • Cross-Border Services and Employment Tax Issues (PowerPoint slides)
    Narendra Acharya, Anne G. Batter, Candace B. Ewell
  • PwC Tax Insights: Trump Administration Officials Announce Tax Reform Principles (April 26, 2017)
    Janice A. Mays
  • PwC Tax Insights: The House Republican Blueprint: A Destination-Based Cash-Flow Tax (January 18, 2017)
    Janice A. Mays

Presentation Material


  • Overview of the US International Tax System
    Linda E. Carlisle, John L. Harrington
  • US Persons Operating Outside the United States: Outbound Active Business Operations
    Justin E. Jesse, Andrea Sharetta
  • Lending, Licensing, and Portfolio Investments: Outbound Investments
    Ethan A. Atticks, Corey M. Goodman
  • International Tax Reporting and Dealing with Noncompliance
    Robert M. Temin
  • The IRS Reached the Expert Level in Offshore Matters: Tax Professionals Must Be Aware of the Remediation Options for Undisclosed Offshore Assets
    Josh O. Ungerman
  • Relieving and Avoiding Double Tax
    Matthew M. Chen, Carol P. Tello
  • Section 987 Foreign Branch Regulations
    Philip B. Wright
  • Selected Issues Related to Outbound Transfers of Intangible Property under Section 367(d)
    Jose E. Murillo
  • Foreign Persons Investing in the United States – Active Business Investments
    John D. Bates, David L. Forst
  • Foreign Persons Investing in the United States (Inbound Investments)
    Jeremy M. Naylor, James S.H. Null
  • Transfer Pricing
    Neal M. Kochman, Melody H. Leung
  • Cross-Border Services and Employment Tax Issues
    Narendra Acharya, Candace B. Ewell
  • International Tax Aspects of Tax Reform
    E. Ray Beeman, Janice A. Mays
Co-Chair(s)
Linda E. Carlisle ~ Chief Operating Officer & General Counsel, Unicom Capital LLC
John L. Harrington ~ Dentons US LLP
Speaker(s)
Narendra Acharya ~ Baker &McKenzie LLP
John D. Bates ~ Deloitte Tax LLP
E. Ray Beeman ~ Washington Council Ernst & Young
Karen J. Cate ~ Tax Law Specialist; Office of the Associate Chief Counsel (International), Internal Revenue Service
Frank (Chip) W. Dunham III ~ Attorney, Branch 6; Office of the Associate Chief Counsel (International), Internal Revenue Service
David L. Forst ~ Fenwick & West LLP
Corey M. Goodman ~ Cleary Gottlieb Steen & Hamilton LLP
Justin E. Jesse ~ McDermott Will & Emery LLP
Neal M. Kochman ~ Caplin & Drysdale, Chartered
Jeremy M. Naylor ~ Proskauer Rose LLP
James S.H. Null ~ Eversheds Sutherland (US) LLP
Andrea Sharetta ~ Dentons US LLP
Carol P. Tello ~ Eversheds Sutherland (US) LLP
Robert M. Temin ~ Rödl Langford de Kock LP
Josh O. Ungerman ~ Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
Philip B. Wright ~ Bryan Cave Leighton Paisner LLP
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