On-Demand   On-Demand Web Programs

International Tax Issues 2017

Released on: Feb. 13, 2017
Running Time: 06:31:22

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. 
  
In this year’s program we assembled 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 non-U.S. based organizations and investors. 
 
You will learn:

  • Explore developing international tax reform legislation in a post-election world, identifying the key concepts and predicting the future
  • Understand the nuances of dealing with international joint ventures
  • Identify cross-border merger and acquisition issues, techniques and developments, including the new Section 7874 regulations
  • Review the developments related to inter-company debt
  • Examine recent administrative and judicial developments in transfer pricing
  • Consider the impact of OECD developments on BEPS, and developments in the U.S. model treaty

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 will benefit from this program.

Lecture Topics [Total time 06:31:22]

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


  • Introduction* [00:02:56]
    Michael A. DiFronzo
  • Inbound Planning and Developments [01:07:27]
    Peter A. Glicklich, Oren Penn, John D. Bates
  • Developments on Transfer Pricing [01:02:32]
    David J. Canale, Rocco V. Femia, Thomas M. Zollo
  • Cross-Border M&A Planning and Developments [01:30:10]
    Diana S. Doyle, John J. Merrick, Eric B. Sensenbrenner, T. Timothy Tuerff
  • Foreign Tax Credits and Subpart F Planning and Developments [01:34:01]
    Gretchen T. Sierra, Stephen R.A. Bates, David Sotos
  • Cross-Border Partnership Planning and Developments [01:14:14]
    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
  • Proposed Regulations Make It Easier for Controlled Entities of Foreign Governments to Access the Benefits of Section 892 of the Code (November 3, 2011)
    Peter A. Glicklich
  • U.S. Tax Extenders Make Major Revisions to FIRPTA and REIT Rules (December 21, 2015)
    Peter A. Glicklich
  • IRS Proposes Broad Limit on Intercompany Debt (April 8, 2016)
    Peter A. Glicklich
  • Will Canadian Pension Plans Feast on U.S. Infrastructure (Without FIRPTA)?
    Peter A. Glicklich, Heath Martin, Abraham Leitner
  • Determining the Form of PCT Payments
    Stephen Blough, Thomas M. Zollo
  • Background, Summary, and Implications of the OECD/G20 Base Erosion and Profit Shifting Project (JCX-139-15)
  • Latham & Watkins Client Alert Commentary: Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules, Number 1956 (April 21, 2016)
    Diana S. Doyle
  • Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments, No. 2023 (October 26, 2016)
    Diana S. Doyle
  • Formation and Use of Hybrid Entities in Cross Border Transactions (November 18, 2016)
    T. Timothy Tuerff, Reed Kirschling
  • IRS Provides Roadmap for Examining Subpart F Foreign Base Company Income Functional Analysis (February 19, 2016)
    David J. Sotos
  • EU Fiscal State Aid—A Briefing Document (October 15, 2014)
    David J. Sotos
  • Foreign Tax Credit Guidance under Section 909 Related to Foreign-Initiated Adjustments; Notice 2016-52
    David J. Sotos
  • Notice 2016-52 Details Section 909 Regulations for FTC Splitting Events Arising from Foreign-Initiated Adjustments Such as EU State Aid (September 19, 2016)
    David J. Sotos
  • In Search of a Normative Theory of Partnership Taxation for International Tax (or How We Learned to Stop Worrying and Love Subchapter K)
    Christopher Trump, Mark A Graham

Presentation Material


  • Inbound Planning & Developments
    John D. Bates, Peter A. Glicklich, Oren Penn
  • Developments on Transfer Pricing
    David J. Canale, Rocco V. Femia, Thomas M. Zollo
  • Cross-Border Acquisitions
    Diana S. Doyle, Eric B. Sensenbrenner, T. Timothy Tuerff
  • Foreign Tax Credits and Subpart F Planning and Developments
    Stephen R.A. Bates, Gretchen T. Sierra, David Sotos
  • Cross-Border Partnership Planning and Developments
    Jennifer H. Alexander, Peter H. Blessing, Joseph M. Calianno, Karen Lohnes
Chairperson(s)
Speaker(s)
John D. Bates ~ Baker & Hostetler 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
John J. Merrick ~ Senior Level Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Oren Penn ~ PwC
Eric B. Sensenbrenner ~ Skadden, Arps, Slate, Meagher & Flom LLP
Gretchen T. Sierra ~ Deloitte Tax LLP
T. Timothy Tuerff ~ Deloitte Tax LLP
Thomas M. Zollo ~ KPMG LLP
General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.

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.


U.S. MCLE States

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

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

Arizona:  PLI’s on-demand web programs qualify as “interactive CLE” credit. There is no limit to the number of credits an attorney can earn via interactive CLE programs.

Arkansas:  PLI’s on-demand web programs are not approved for Arkansas CLE credit.

California:  PLI’s on-demand web programs qualify as “participatory” credit. There is no limit to the number of credits an attorney can earn via participatory programs.

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

Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s on-demand web programs qualify as “eCLE” credit. Attorneys are limited to 12 credits of eCLE per reporting period, no more than 6 of which may be audio-only.

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

Georgia:  PLI’s on-demand web programs qualify as “in-house” credit. Attorneys are limited to 6 in-house credits per reporting period.

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

Idaho:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 15 credits of self-study per reporting period.

Illinois:  All PLI products can fulfill Illinois' CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Indiana:  PLI’s on-demand web programs qualify as “distance education” credit. Attorneys are limited to 9 credits of distance education per reporting period.

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

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

Kentucky:  PLI’s on-demand web programs qualify as “non-live” credit. Attorneys are limited to 6 non-live credits per reporting period.

Louisiana:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 4 credits of self-study per reporting period.

Maine:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 5.5 credits of self-study per reporting period.

Minnesota:  PLI’s on-demand web programs qualify as “on-demand” credit. Attorneys are limited to 15 on-demand credits per reporting period.

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

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

Montana:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 5 credits of self-study per reporting period.

Nebraska:  PLI’s on-demand web programs qualify as “computer-based learning” credit. Attorneys are limited to 5 credits of computer-based learning per reporting period.

Nevada:  PLI’s on-demand web programs qualify as “self-study” credit. There is no limit to the number of credits an attorney can earn via self-study programs.

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

New Jersey:  PLI’s on-demand web programs qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

New Mexico:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 4 credits of self-study per reporting period.

New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

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.

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

North Dakota:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 15 credits of self-study per reporting period.

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

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

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

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

Puerto Rico:  PLI’s on-demand web programs qualify as “non-traditional” credit. Attorneys are limited to 8 credits of non-traditional programs per reporting period.

Rhode Island:  PLI’s on-demand web programs qualify as “on-demand” credit. Attorneys are limited to 3 on-demand 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.

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

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:  PLI’s on-demand web programs qualify as “A/V” credit. Attorneys are limited to 22.5 credits of A/V programs per reporting period.

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.”

Ontario (CPD-ON):  PLI’s on-demand web programs qualify as “recorded” credit. If viewed without a colleague, attorneys are limited to 6 credits of recorded programs per year. If viewed with at least one colleague, there is no limit to the number of credits that can be earned via recorded programs.

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.


Other Credit Types

CPE Credit (NASBA):  Select on-demand web programs qualify as “QAS Self-Study” credit. 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).

Certified Fraud Examiner CPE:  PLI’s on-demand web programs may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

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.

 

Related Items

Live Programs  Live Programs

Basics of International Taxation 2018 (San Francisco, CA) Sep. 27 - 28, 2018
International Tax Issues 2018 (Chicago, IL) Sep. 5, 2018
Basics of International Taxation 2018 (New York, NY) Jul. 24 - 25, 2018
International Tax Issues 2018 (New York, NY) Feb. 6, 2018

On-Demand  On-Demand Programs

Basics of International Taxation 2017 San Francisco Sep. 26, 2017
Basics of International Taxation 2017 Aug. 4, 2017

Handbook  Course Handbook Archive

Basics of International Taxation 2018  
International Tax Issues New York City 2018  
International Tax Issues 2017 Lowell D Yoder, McDermott Will & Emery LLP
 
Basics of International Taxation 2017 Linda E Carlisle, Miller & Chevalier Chartered
John L Harrington, Dentons US LLP
 
International Tax Issues 2017 Michael A DiFronzo, PwC
 
International Tax Issues 2016 (Chicago) Lowell D Yoder, McDermott Will & Emery LLP
Lowell D. Yoder, McDermott Will & Emery LLP
Sean P. Thompson, 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
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
Brian H. Jenn, U.S. Department of the Treasury
 
Share
Email

  • FOLLOW PLI:
  • twitter
  • LinkedIn
  • GooglePlus
  • RSS

All Contents Copyright © 1996-2017 Practising Law Institute. Continuing Legal Education since 1933.

© 2017 PLI PRACTISING LAW INSTITUTE. All rights reserved. The PLI logo is a service mark of PLI.