1-Day Program

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Overview

Why You Should Attend

As the world’s economies emerge from the economic devastation of COVID-19 and countries seek to increase their tax base, navigating the U.S. international rules remains imperative for those doing business and making investments cross-borders.  These international tax rules affect not only large U.S. and non-U.S. based multinationals, but also increasingly affect mid-sized and smaller organizations and investors, financing transactions, mergers and acquisitions, and other commercial activity.  A working knowledge of these international tax rules is of paramount importance to a wide variety of tax professionals.

At this year’s program we will assemble some of the world’s leading experts and senior government officials to discuss the complex rules of U.S. international taxation in light of the 2017 Tax Act (formerly the Tax Cuts and Jobs Act – “TCJA”), as well as developments resulting from the 2020 U.S. presidential and congressional election and the business and tax authority responses to the economic fallout from COVID-19.  We will focus upon both operational and transactional implications of the changed rules and environment, and describe the application of the rules to both U.S. and non-U.S. based organizations and investors.

Topics Include

  • Transfer pricing developments and transfer pricing’s role in new global intangible low-taxed income (“GILTI”) and foreign-derived intangible income (“FDII”) provisions
  • The impact of OECD developments, treaty developments and the new base erosion anti-abuse tax (“BEAT”) and hybrid provisions included in the TCJA
  • Cross-border merger and acquisition issues, techniques and developments, including the Section 245A regulations
  • Changes to the anti-deferral rules, foreign tax credits and FDII
  • Dealing with international joint ventures, revisiting fund structures and the new paradigm shift for the partnership form

 

Who Should Attend

Law firm and accounting firm professionals who advise clients on structuring cross border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and internal planning, in FIN 48 determinations and in IRS audits and appeals of international issues; and government attorneys who want to stay on top of what’s happening in the international tax arena will benefit from attending this program.

 

Program Level – Overview

Intended Audience - Law firm and accounting firm professionals who advise clients on structuring cross border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and internal planning, in FIN 48 determinations and in IRS audits and appeals of international issues; 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 and an interest in staying on top of what’s happening in the international tax arena.

Advanced Preparation - None

 

Credit Details

Schedule & Location

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