transcript   Transcript

Inbound Planning and Developments

Recorded on: Feb. 8, 2017
Running Time: 01:07:27

Full Transcript:

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CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Lecture Topics [01:07:27]

Upon the successful completion of this program, the participant will be able to:

  • Identify key aspects of recent U.S. tax reform efforts and their potential impact on inbound investment.
  • Recognize the critical differences between the Proposed and Final Regulations issued under IRC §385 and their potential impact on inbound investment.
  • Recall recent tax treaty proposals.


Course Overview:

This program will focus on:

  • Recently proposed U.S. tax reform efforts.
    • The U.S. House of Representatives’ GOP Blueprint
    • The Trump Tax Plan
  • The Proposed and Final Regulations issued under IRC §385 and their potential impact on inbound investment.
    • The Bifurcation Rule
    • Documentation Rules
    • Transactional Rules
  • Proposed U.S. tax treaties.
    • The 2016 U.S. Model Income Tax Convention
    • The Organization for Economic Cooperation and Development’s (OECD) Multilateral Treaty Instrument (MLI)
  • Implications of tax reform on FIRPTA


CPE Program Level:


Intended Audience:

Law firm and accounting firm professionals advising clients on structuring cross-border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and international tax planning; and government attorneys seeking the latest developments in the international tax arena.


A background in the taxation of cross-border transactions, and international tax planning and controversy matters.

Advanced Preparation:


Instructional Method:

QAS Self-Study


February 2017

John D Bates ~ Baker & Hostetler LLP
Peter A Glicklich ~ Davies Ward Phillips & Vineberg LLP
Oren Penn ~ PwC
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