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

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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 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 ...

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 ...

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 ...

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 ...

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 ...

Foreign Tax Credits and Subpart F Planning and Developments

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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, ...

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

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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

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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 ...

Basics of International Taxation 2018 New York

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From the program: Basics of International Taxation 2018

Released on: Aug. 1, 2018

In a global business environment, transactions with customers and suppliers often transcend national borders and investment and activities are frequently cross-border as well.   An understanding of the U.S. international tax rules--especially after enactment of the Tax Cuts and Jobs Act--is of paramount importance to a wide variety of tax and corporate professionals.    This year’s program will be led by international tax ...

Tax Concerns of U.S. Persons Investing or Operating Outside the U.S. (Outbound Investment Rules) - Income Not Subject to Deferral or Exemption

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

JOHN BATES: Well, thank you all for joining us this morning. I usually at some point in time end up off script, so I figured I might as well just start off script today. Linda was mentioning a tax terminology, I was canvassing Kristi and Jose this morning about what term they use for Net Deemed Tangible Income Return, which is a topic that we will get to later today. Neither of them had an answer. So if you think about it and you come up with something ...

Impact of Tax Reform on U.S. Individuals with Business Operations Outside the U.S.

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

LINDA E. CARLISLE: Good afternoon. Well, we're ready to start again this afternoon. And this time, we are going to deal with the impact of US tax reform, or whatever that thing was called that happened in 2017, its impact on business operations outside of the United States. This we'll continue our discussion of GILTI, of changes to the foreign tax credit, and of all things international. To lead us in this discussion, I've got two brilliant and accomplished ...

Tax Concerns of U.S. Persons Investing or Operating Outside the U.S. - Partnerships

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

LINDA E. CARLISLE: All right, we are ready. We are in the home stretch. And I'm just going to whisper this, but we do kind of try to save the best for last. What can I say? All right, this particular panel is going to be talking about continuing our discussion of outbound investments. But this time, we're really going to focus on outbound investments through partnerships and the US tax considerations of those kind of activities outside the United ...

Tax Concerns of Foreign Persons Investing in the United States - Active Investments

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

JOHN L. HARRINGTON: Thanks. Welcome back to day 2 of PLI's Basics of International Taxation. Yesterday, we focused primarily on outbound investments by US taxpayers, particularly in light of the changes made by tax reform. This morning, we're going to focus on the other side of international tax rules, and those are the rules for inbound investment by non-US persons. Now, our first panel is going to enlighten us on the tax concerns of foreign persons ...

Tax Concerns of U.S. Persons Investing or Operating Outside the U.S. (Outbound Investment Rules) - Mitigating Double Taxation and Special Rules

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

LINDA E. CARLISLE: Welcome back. We are now going to focus on what do we do after we have found that we have Subpart F income and now we have GILTI income, we are just guilty as can be. And how do we avoid double taxation? Because remember, we are now dealing with a new regime. And as Jose said in our last panel, this is a regime aimed at increasing the US tax base. And so now that we've increased the US tax base, we have to worry even more about ...

Tax Treaties and Dispute Resolution

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

JOHN L. HARRINGTON: Now we move on from transfer pricing specifically to tax treaties and dispute resolution more generally. Joining me is Nicole Welch. I'm filling in for Heather Malloy. But Nicole is the senior manager of the IRS's Treaty Assistance and Interpretation team. Which, as we've discussed before, like many things in the international tax world, has its own acronym, TAIT. TAIT is responsible for all non transfer pricing interpretive matters ...

Tax Concerns of Foreign Persons Investing in the United States - Funds and Passive Investments

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

JOHN L. HARRINGTON: Thank you, everyone. It's now time to continue our march through the tax concerns of foreign persons investing in the United States. The previous panel focused on we'll call the active investment, sort of like acting directly or through sort of a controlled entity. Our next panel is going to focus on sort of funds and passive investments. There's lots to be overlapped between the first panel and the second panel, but the focus ...

Tax Concerns of U.S. Persons Investing or Operating Outside the U.S. - U.S. Corporations

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

LINDA: I like it. I like it. That's good. All right, our next panel, come on up. Our next panel is going to talk about US tax considerations for US corporations investing or operating outside of the United States. Thank you. And to lead us in this discussion we have got two great people. All right, Corey Goodman and Carolyn Ngo. OK who's going to start? Are you going to start, Carolyn? CAROLYN NGO: Yes. LINDA: Well then I'm going to introduce Carolyn ...


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