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Showing 1 - 25 of 27 Results

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IRS and Treasury’s New Guidance Issued Under Sections 7874 and 385

MP3 Audio  Audio Download (MP3)    Audio Only On-Demand Web  On-Demand One-Hour Briefing    

Recorded on: Apr. 29, 2016

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Lecture Topics [01:01:32] Upon the successful completion of this program, the participant will be able to: Understand inversion transactions and the potential impact on certain-publicly traded companies stemming from federal regulation of inversions. Recall the New Provisions under section 7874 impacting inversion ...

Basics of International Taxation 2016 -- Overview of U.S. International Tax System

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

From the program: Basics of International Taxation 2016

Recorded on: Jul. 21, 2016

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam. Lecture Topics [01:05:25] Upon the successful completion of this program, the participant will be able to: Understand the general rules regarding U.S. income taxation of worldwide income earned by both U.S. and non-U.S. persons. Recognize the U.S. federal income tax treatment of U.S. persons with regard to foreign ...

International Tax Issues 2017 -- Inbound Planning and Developments

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

From the program: International Tax Issues 2017

Recorded on: Feb. 8, 2017

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 ...

Cross-Border Partnership Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 8, 2017

MICHAEL DIFRONZO: So thank you all for getting back. This is our last panel. And that doesn't mean it is our least panel at all. This is always an exciting panel, dealing with partnerships. KAREN LOHNES: Oh, Jesus. Don't get choked up. MICHAEL DIFRONZO: It's so exciting, I'm choking. PETER BLESSING: He's all choked up. KAREN LOHNES: Oh, man. MICHAEL DIFRONZO: Funny how that happens. JOSEPH CALIANNO: Yeah. Thank you. MICHAEL DIFRONZO: Wow. OK. ...

Developments on Transfer Pricing

Transcripts  Transcripts    

Recorded on: Feb. 8, 2017

SPEAKER 1: So excited to do our transfer pricing panel here. We have an esteemed group that's been here for many years with us. It's the same group. The first person entering is David Canale. David is the Global Head of Transfer Pricing for EY. Moving behind him in the middle is Rocco Femia. Rocco is with Miller & Chevalier. Rocco writes a lot on transfer pricing issues. He's very thoughtful. Been around for a long time, both of them prior government ...

Foreign Tax Credits and Subpart F Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 8, 2017

MICHAEL A. DIFRONZO: Good afternoon and welcome back to our international tax program. We are going to begin the afternoon with our next panel, which is on Foreign Tax Credits and Subpart F, sort of a funny combination, but again, we're trying to put a lot of information into the day. And you know, they're both outbound topics so why not combine them. It's interesting though when you try to put that panel together, you need to find some people who ...

Inbound Planning and Developments

Transcripts  Transcripts    

Recorded on: Feb. 8, 2017

OREN PENN: Great. Thank you, Mike. So what we'll do is, over the next hour, we're going to cover four main topics. You're probably hearing a lot about US tax reform. What's going to happen? We want to look at it, spend a few minutes on that topic from the standpoint of how it impacts an inbound company, if we're a multinational that invests into the US. So we're going to spend a little time talking about the summary of what the proposals are, but ...

Basics of International Taxation 2017 -- International Tax Aspects of Tax Reform

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

From the program: Basics of International Taxation 2017

Recorded on: Jul. 20, 2017

Taken from the Web Program Basics of International Taxation 2017 New York City recorded July, 2017 in New York. International Tax Aspects of Tax Reform [01:15:32] Possible changes to US international tax rules Transition Rules Tax planning in anticipation of legislation E. Ray Beeman, Janice A. Mays The purchase price of this segment includes the following article from the Course Handbook available online: PwC Tax ...

International Tax Aspects of Tax Reform

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: Thanks. That was the first reward for staying all the way through the end of the conference. The second reward is getting to hear our two distinguished panelists talk about the international aspects of tax reform. And this is a very hot topic. It's hard to make a lot of sense of it. So they're both going to do their best at doing that. In this case, we're fortunate to have, at my far left, Janice Mays. Janice is the managing director ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA CARLISLE: Now that we have a basic understanding of the international tax rules, or at least how they're intended to operate, we're going to get to the real nitty gritty of how they do operate. And we have five more panels today that will go through the specifics of how US taxes outbound and inbound transactions. Now tomorrow, we'll deal with inbound transactions, and investments, and transfer pricing, and cross-border, and the diseases we were ...

Cross-Border Services and Employment Tax Issues

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN HARRINGTON: So now we go from discussing transfers of property and services to discussing transfers of people. So we have our next panel is going to talk about the cross-border services and employment tax issues. So we have two panelists who will come up as soon as they get a chance. Apologies. There'll be a break following this one. While they're getting settled in, I'll introduce our two panelists. To my left is Anne Batter. She's a partner ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA E. CARLISLE: Well, welcome back. Our next panel is going to deal with the tax concerns of US persons investing or operating outside the United States through more passive investments. Remember, our last panel talked about the active businesses. Now, we're going to talk about passive-- lending, licensing, portfolio investments. And to lead us in this discussion, I couldn't be more pleased to have these two terrific people-- Ethan Atticks and ...

International Tax Reporting and Dealing with Noncompliance

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA E. CARLISLE: Welcome back, everyone. I hope you had a good break and are ready for an afternoon of more excellent presentations. Our next panel is going to deal with international tax reporting and how the IRS deals with noncompliance. As we know, tax reporting by US persons with foreign income is required and is receiving a great amount of attention in recent years. Bob Temin and Josh Ungerman will tell us what forms will need to be filed and ...

Outbound Transfers of Intangible Assets and Treatment of Foreign Currency

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

LINDA CARLISLE: Well, we're back. And, as I said, we really are saving the best for last. This is a brand new panel this year where we are going to talk about outbound transfers of intangible assets, and the treatment of foreign currency. We are so very, very lucky to have Jose Murillo and Phil Wright tell us about these issues. Truly we're saving the best for last. Jose is a partner at EY where he heads EY's international tax services group focusing ...

Overview of U.S. International Tax System

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: For our first panel, like I said, this is intended to be kind of an overview of the US international tax rules. And I'll just start off with the two basic general rules. The US persons are subject to tax on their worldwide income, US tax and worldwide income. Non-US persons are typically taxed only on their US source income. Now, if that was all to these rules, you wouldn't be here for two days. So there's obviously a lot of sort ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: Thank you. Welcome back, everyone. We just finished our first in-bound panel dealing with sort of what we call active business investments. And now our second panel for the morning will deal with the in-bound investments from a passive investment standpoint. And we have two excellent panelists here. To my immediate left is Bill Corcoran. He's a partner at Cooley LLP in Boston. And he represents leveraged buyout, venture capital, ...

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

Transcripts  Transcripts    

Recorded on: Jul. 20, 2017

JOHN L. HARRINGTON: Good morning, everyone. Welcome back to day two of PLI's Basics of International Taxation. As you may recall, yesterday we talked about the impact of the US tax rules on outbound investments. This morning we're going to focus on the US tax rules that apply to the tax concerns of persons investing inside the United States-- inbound investments. And then later on this afternoon, we'll turn to some things that affect both inbound ...

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 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 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 ...

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 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 ...


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