transcript   Transcript

Inbound Planning and Developments

Recorded on: Feb. 9, 2018
Running Time: 01:10:18

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Taken from the Web Program International Tax Issues 2018 held February 2018 in New York

Inbound Planning and Developments [01:10:17]

  • Section 163(j) as applied to inbound investment
  • New anti-hybrid rules
  • Base erosion and anti-abuse tax("BEAT") as applied to inbound investment
  • BEPS and OECD developments affecting inbound structures
  • PATH impact on FIRPTA
  • Section 385 debt/equity developments
  • Current foreign fund investment issues
  • Treaty developments – U.S. Model Treaty and new treaty negotiations

Peter A. Glicklich, Oren S. Penn, Paul M. Schmidt

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

  • House Republicans Moving Forward on U.S. Tax Reform (November 3, 2017)
    Gregg M. Benson, Peter A. Glicklich
  • The Path to Tax Reform 2017: Long-Awaited Tax Cuts and Jobs Act Released by House Ways & Means Committee for Potential Passage This Year (November 3, 2017)
    Paul M. Schmidt

Presentation Material
  • Inbound International Tax Issues with a Focus on Tax Reform 2017
    Peter A. Glicklich, Oren Penn, Paul M. Schmidt
    (s)
    Peter A. Glicklich ~ Davies Ward Phillips & Vineberg LLP
    Oren Penn ~ PwC
    Paul M. Schmidt ~ Baker & Hostetler LLP
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