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Showing 1 - 25 of 34 Results


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

MP3 Audio  Audio Download (MP3)    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 ...

The Tax Cuts and Jobs Act: Navigating the New Landscape -- The International Tax Reform Provisions—Part 1

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

Recorded on: Feb. 5, 2018

Taken from the Web Program The Tax Cuts and Jobs Act: Navigating the New Landscape Recorded February 2018 in New York The International Tax Reform Provisions—Part 1 [01:12:25] CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. While this program offers CPE (NASBA) credit, it has expired for CLE credit in many states. Please check the credit calculator to the right. ...

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 ...

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 ...

International Estate & Tax Planning 2018 -- New Tax Law Changes as They Affect Tax Planning for International Private Clients

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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 New Tax Law Changes as They Affect Tax Planning for International Private Clients [01:00:04] Overview of international tax law changes affecting private clients, including: Transition Tax Global Intangible Low-Taxed Income (GILTI) Foreign Derived Intangible Income (FDII) Expansion of constructive ownership ...

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 ...

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 ...

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 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 ...

Transfer Pricing

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

JOHN HARRINGTON: Welcome back. Based on the assumption no one wants to face transfer pricing on an empty stomach, we're ready to move on to the afternoon panels. The first panel will be on transfer pricing. And here again we've got a great lineup of people to walk you through the transfer pricing issues. To my left is John Warner, who's a shareholder in Buchanan, Ingersoll, and Rooney. John is co-chair of the Business and International Tax Practice ...

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 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 ...

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 ...

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 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 ...

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 ...

Predictions for the Future of International Tax Law

Transcripts  Transcripts    

Recorded on: Jul. 26, 2018

CATHERINE G. SCHULTZ: [INAUDIBLE] [PHONE RINGING] JOHN L. HARRINGTON: Thank you. Thank you. And then the other prize is we're on our last panel, so I'm-- [LAUGHTER] JOHN L. HARRINGTON: And so thank you again for all your patience. But this is a very important panel. And we've heard a lot about the tax reform, the impact that it's had on things. And so now the questions are going to be, what happens next? There's guides that has come out. There ...

Tax Treaties and Dispute Resolution

Transcripts  Transcripts    

Recorded on: Oct. 1, 2018

JOHN: While our panelists are getting settled, I'll go ahead and start the introductions just to maximize the time they can provide. But coming right up aboard to my right will be Frank Ng of EY. Frank is a member of EY's tax controversy and risk management services group in Washington DC. We assist clients focused on working effectively with the IRS, and tax administrations around the world dealing with issues. And to his right as Greg Texley with ...

Transfer Pricing

Transcripts  Transcripts    

Recorded on: Oct. 1, 2018

SPEAKER: OK. I know people are coming back from lunch. But we'll go ahead and start up and let people come in as in progress. But now we start the last afternoon of the program. So again, we appreciate your patience and perseverance. Our very next panel is on-- we discussed the outbound, we discussed the in-bound. Now we're talking about something that really relates to really potentially inbound and outbound, and that's transfer pricing. And with ...

Predictions for the Future of International Tax Law

Transcripts  Transcripts    

Recorded on: Oct. 1, 2018

JOHN: OK, thank you. So that was our first winner. Now, our second winners are the rest of you, because you get to hear our-- JANICE A. MAYS: Lucky you, on a Friday afternoon. CATHERINE G. SCHULTZ: Yup, last panel. JOHN: Yes. You get to hear our final panel. This is on the predictions of the future of international tax law. And we've got two excellent panelists here. We have Janice. To my right is Janice Mays, who's the managing director in PwC's ...

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: Oct. 1, 2018

SPEAKER 1: Thank you all. And welcome back. We're going to return to our panels on the impact of the investing from an outbound standpoint. And we've got a great panel here that's going to focus on the mitigating double taxation and the vague and always catch all term is special rules. And with that, I think we're very fortunate to have two of the, to me, the best people to be running through these particular rules. To my right arm Danielle Rolfes, ...

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

Transcripts  Transcripts    

Recorded on: Oct. 1, 2018

JOHN: OK. Well, I know people are still coming back in from the break, but since it's 10:45, we'll go ahead and start up our second panel on inbound issues. And for this panel, we're fortunate to have, to my right, Michele Alexander, who's a partner at Bracewell LLP. And Michele provides counsel in a wide range of transactions from mergers and acquisitions, capital markets and securities offerings, to financing joint ventures and restructurings, and ...


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