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As the world’s economies grow increasingly integrated through trade, acquisitions and joint ventures, and global taxation becomes more aligned, U.S. international tax laws impact a greater percentage of businesses and transactions. 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”). We will focus upon both operational and transactional implications of these rules, and describe the application of the rules to both U.S. and non-U.S. based organizations and investors.
- 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 new Section 245A temporary 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
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