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Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments

MP3 Audio  Audio Download (MP3)    Web Segment  Web Segment    MP4 - Mobile Video Seg  Video Download (MP4)    

Recorded on: Jul. 20, 2017

Taken from the Web Program Recorded July 18 - 19, 2017 in New YorkTax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments [01:32:34]• Effectively Connected Income (ECI) and permanent establishment consequences • Branch profits tax imposition John D. Bates, S. Eric WangThe purchase price of this Web Program segment includes the following article from the Course Handbook available ...

Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) – Lending, Licensing and Portfolio Investments

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

JOHN L. HARRINGTON: We'll start our next panel. And this is on task concerns for US persons investing or operating outside the United States-- lending, licensing, and portfolio investments. And here we're fortunate to have two great panelists. To my right is Ethan Atticks, who is an international tax services managing director in the Washington National Tax Services Office of PWC, where he specializes in outbound international tax issues with a focus ...

International Tax Reporting and Dealing with Noncompliance

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

JOHN L. HARRINGTON: I would like to invite everyone back into the conference room. I hope everyone had a good lunch. And we'll still go through the-- to hear about international tax reporting and dealing with noncompliance. And here again we have two great panelists here. To my right is Bob Temin. He's a partner at the Atlanta tax practice of Rodl Langford de Kock. It's a US affiliate of Rodl & Partner. And Bob's practice focuses on international ...

Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Passive Investments & U.S. Withholding and Reporting

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: All right. Well, we're back. We're going to now shift from looking at effectively connected income to more passive types of income, and how the United States taxes that type of income in an inbound transaction. Now, to do that, and to explain everything to us, I couldn't be more pleased to have Jamie Null and Jeremy Naylor with us. Jamie is a partner, or shareholder, I think I have to say that correctly, at Greenberg Traurig in ...

Cross-Border Services and Employment Tax Issues

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: --it. Because now we're going to talk about cross-border services and employment tax issues. Now, this is, to me, something that is not discussed, but at least has come up in my practice way too many times and I haven't known what to do, OK? But that is the reason I've got Candace Ewell here and I've got Narendra Acharya here. Narendra to my right-right is a partner in the Chicago office of Baker and McKenzie and member of the firm's ...

Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

DAVID L. FORST: Start off, Linda? LINDA E. CARLISLE: Yeah, I'll introduce you. OK. Good morning. Welcome to our second day of our mini LLM. Today we're going to focus on inbound investments. We're going to continue our discussion as we drill into transfer pricing, cross-border services, and we'll conclude today with a discussion of what might happen to all the rules that we talked about yesterday and today if international tax reform does take place. To ...

Outbound Transfers of Intangible Assets and Treatment of Foreign Currency

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

[MUSIC PLAYING] LINDA E. CARLISLE: Welcome, everyone, back after the break. It was a little bit less than 10 minutes. But we have the panel you've all been waiting for-- the final panel of the day. And it's dealing with outbound transfers of intangible assets and foreign currency. And here we're fortunate in the first part of that to have Jose Murillo, who is national tax partner and leads Ernst & Young International Tax Services Group in Washington ...

International Tax Aspects of Tax Reform

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

JOHN L HARRINGTON: OK, I'd like to welcome everyone back for the final panel of the day, dealing with international tax acts aspects of tax reform. But before I introduce the panel, I do want to remind you to please, if you haven't already, to fill out the evaluations. Those are very important to us in terms of being able to see what works, what doesn't work, and terms of having a program that's responsive to your needs and interests. So please do ...

Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) – Active Business Operations

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: OK, our first panel is going to deal with the tax concerns for US persons investing or operating outside the United States. Remember, we're using the magic term US persons outside the United States. I'm going to leave and let these people take over, but I'm going to tell you how wonderful they are. Andrea, here. Please sit here. Andrea is one of John's partners. She is a partner at Denton's tax practice in New York, where she has ...

Overview of U.S. International Tax System

Transcripts  Transcripts    

Recorded on: Sep. 21, 2017

LINDA E. CARLISLE: We'll first start with a general overview of the US international tax system and even though I just said we have preeminent tax lawyers explaining everything to you, John and I are going to start off, OK. So we will, maybe not the most preeminent, but we will start it off so that the preeminent people can elaborate. JOHN L. HARRINGTON: I mean, some of this will be quite basic. I mean some of these will be familiar to you but the ...

Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017 -- Cross-Border Mergers, Post-Acquisition Integration and Other International Issues

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From the program: Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017

Recorded on: Oct. 27, 2017

Taken from the Web Program Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017 recorded October 2017 in New York. Cross-Border Mergers, Post-Acquisition Integration and Other International Issues [01:58:00] Mergers with U.S. parent companies; mergers with foreign parent companies; exchangeable share structures; use of hybrids; debt/equity developments; inversion ...

The Tax Cuts and Jobs Act: Navigating the New Landscape -- The International Tax Reform Provisions—Part 2

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From the program: The Tax Cuts and Jobs Act: Navigating the New Landscape

Recorded on: Feb. 5, 2018

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Upon the successful completion of this program, the participant will be able to: Recall the operation of the base erosion and anti-abuse tax (BEAT) provisions imposed pursuant to Internal Revenue Code (IRC) §59A. Identify some of the questions surrounding the implementation of the base erosion and anti-abuse tax (BEAT) ...

The International Tax Reform Provisions—Part 2

Transcripts  Transcripts    

Recorded on: Feb. 5, 2018

DAVID SCHNABEL: OK, I think we're going to get started with our second international panel. Just to introduce the people, we have two people joining via video, Jennifer Acuna, who's a Senior Tax Counsel and Policy Adviser at the Senate Finance Committee. We've got Manal Corwin, who has the coolest title of all. She's at KPMG and is the National Service Line Leader for International Tax as well as the principal in charge of the Washington National ...

The International Tax Reform Provisions—Part 1

Transcripts  Transcripts    

Recorded on: Feb. 5, 2018

DAVID H. SCHNABEL: So just introduce the first panel, Neil Barr, my partner at Davis Polk is going to moderate it. Joining Neil will be John Harrell, who is the global tax director at GE Capital, Aaron Junge, a tax counsel the House Ways and Means is joining via webcast. Marjorie Rollinson, Associate Chief Counsel International is also here, as well as Brenda Zent, Special Advisor to the International Tax Counsel. And of course, Dana. So Neil, you ...

International Tax Issues 2018 -- Developments on Transfer Pricing

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From the program: International Tax Issues 2018

Recorded on: Feb. 9, 2018

Taken from the Web Program International Tax Issues 2018 held February 2018 in New York Developments on Transfer Pricing [01:01:59] Update on transfer pricing practice Transfer pricing aspects of global minimum tax on intangible income ("GILTI") and BEAT BEPS and OECD developments affecting transfer pricing (including, Country by Country reporting) Section 367(d) regulations (transfer pricing aspects) - will the regulations ...

Developments on Transfer Pricing

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL DIFRONZO: OK, so are in our next panel will cover transfer pricing. And they'll make their way up here. Then I'll introduce them. But it's going to be a little different when we talk about transfer pricing, I think, today. No, two Toms. Who's opening? OK. So as they're getting seated, I'm going to introduce them. Rocco Femia is immediately to my left. Rocco is with Millard Chevalier. Rocco served in the United States Treasury International ...

Inbound Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL A. DIFRONZO: So this is an exciting time. I'm going to begin by introducing the first panel, but we have the other subject areas. And I'll introduce them as they come through. This first panel is going to talk about inbound issues-- will focus a lot on tax reform. I do think they'll mention a few other things, like FIRPTA and BEPS or something along the way, but I think much of what they have to say will be about tax reform. So to introduce ...

Foreign Tax Credits and Subpart F Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL DIFRONZO: Hey, welcome back. Our panel is going to continue with the tax reform theme. As I've mentioned before the break, this panel will focus on guilty, It'll also focus on foreign tax credits and some of the other nuances that have already been introduced of these rules, but they're going to dive a little deeper. And I'm very, very pleased to introduce what I consider to be an all-star panel for this. To my immediate left is Chris Trump, ...

Cross-Border M&A Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MARJORIE A. ROLLINSON: It's good to [INAUDIBLE]. MICHAEL A. DIFRONZO: Welcome back. Now we're going to move into our M&A panel. And I would like to introduce our panelists again, starting right to left. I'm pleased to introduce Margie Rollinson. Margie Rollinson is the Associate Chief Counsel International. She has a very, very big job ahead of her this year. Got to write a lot of guidances, really going to help us get through these very complicated ...

Cross-Border Partnership Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 9, 2018

MICHAEL A. DIFRONZO: OK, thank you, Stacy. So we're in the final stretch here, and we've got maybe even a just as complicated topic to discuss as the last one, which is how does all of this shake out in the triangle world or the pass-through world. And also, there are a number of old issues that are still hot in that space. So this panel's going to take us through-- I'm not going to take much of their time. We only have an hour 14 right now to get ...

International Estate & Tax Planning 2018 -- Planning with Foreign Grantor and Nongrantor Trusts

Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: International Estate & Tax Planning 2018

Recorded on: May. 22, 2018

Taken from the Web Program International Estate & Tax Planning 2018 Recorded May 2018 in New York Planning with Foreign Grantor and Nongrantor Trusts [01:15:52] The different U.S. income tax rules for foreign grantor trusts and foreign nongrantor trusts, and the differences between foreign trusts established by U.S. settlors (outbound trusts) and trusts established by foreign settlors (inbound trusts) will be explained Planning opportunities ...

Planning with Foreign Grantor and Nongrantor Trusts

Transcripts  Transcripts    

Recorded on: May. 22, 2018

MEGAN WORRELL: Hi, everyone, and welcome back from lunch. We're going to start out the right after lunch topic with foreign trust. So it's my pleasure to introduce here there's my co-chair today, Dean Berry, and his partner, Robert or Bob Lawrence also Cadwalader. Now Bob, you really don't need much of an introduction. You have every fancy title I can possibly think of. And I'll just really say one thing. Chambers calls Bob-- he's described as one ...

New Tax Law Changes as They Affect Tax Planning for International Private Clients

Transcripts  Transcripts    

Recorded on: May. 22, 2018

MEGAN R. WORREL: The next panel, we have Karen Brodsky here who's a partner at Deloitte. Dave, I was going to pronounce your last name wrong. I'm sorry. David Warco, also a partner at Deloitte. Karen is the Deloitte head of their global private client team. And Dave's practice is international tax, a little more on the corporate side. I've mentioned this before. And personally for me, as a private client lawyer, I work very closely with a corporate ...

Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018 -- International Joint Venture Issues

Web Segment  Web Segment    MP3 Audio  Audio Download (MP3)    MP4 - Mobile Video Seg  Video Download (MP4)    

From the program: Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018

Recorded on: Jun. 7, 2018

Taken from the Web Program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018  Recorded June, 2018 in San Francisco [01:29:45] Impact of the passage of the Tax Cuts and Jobs Act on the choice to conduct business using a domestic or foreign partnership in both the outbound and inbound context, including issues related to the formation, operation and termination of the business Paul ...

International Joint Venture Issues

Transcripts  Transcripts    

Recorded on: Jun. 7, 2018

SPEAKER: All right take your passports out because it's international joint venture time. This panel focuses on international tax issues that arise in structuring and operating joint ventures. Now to be clear, everything that you've learned over the last three days remains very relevant with cross-border joint ventures. We just get to layer on a whole new set of rules. And for this we have Paul Oosterhuis, Chris Trump, and Dan McCall. Paul is of ...


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