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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 2017 Tax Act--is of paramount importance to a wide variety of tax and corporate professionals.
This year’s program will be led by international tax experts and focuses on specific types of outbound and inbound investment and activities, and their U.S. tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the new U.S. tax rules address the issues raised. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities.
What You Will Learn
- How the changes made by the 2017 Tax Act affect choice of entity decisions for U.S. and foreign investors
- The new 100% dividend exemption for domestic corporations owning foreign corporations
- Subpart F and new global intangible low-taxed income (“GILTI”) rules which cause U.S. shareholders in controlled foreign corporations (“CFCs”) to be subject to immediate U.S. tax
- Tax and reporting rules that apply to U.S. subsidiaries of foreign companies
- Background, purpose and history of foreign tax credits
- The mechanics and significance of tax treaties
- Overview of the reporting and withholding requirements in international transactions
- Recognizing Passive Foreign Investment Companies (“PFICs”)
Program Level – Overview
Intended Audience - Corporate, law firm and accounting firm professionals that consider cross-border transactions and need a working knowledge of relevant U.S. international tax rules, and government attorneys who want to stay on top of what’s happening in the international tax arena.
Prerequisites – Familiarity with the U.S rules of international taxation.
Advanced Preparation – None