See Credit Details Below
Overview
Why You Should Attend
As the world’s economies grow increasingly integrated through trade, acquisitions, joint ventures, and even international governmental agreements, 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 Chicago 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 TCJA, including the voluminous regulations that have been issued by the Treasury and IRS implementing the new rules, and OECD developments. We will also explore the significant changes to the international tax rules proposed by the Biden Administration. We will focus upon both operational and transactional implications of these rules and describe their application to both U.S. and non-U.S. based organizations and investors.
What You Will Learn
- Understand the tax consequences of the international tax rules in an economic downturn
- Identify the international tax issues triggered by special purpose acquisition companies (“SPACs”)
- Recognize ways to use business and transactional losses to achieve maximum tax benefits
- Identify circumstances that allow for renegotiation of an existing transfer pricing arrangement in response to changes in economic conditions
- Apply the base erosion anti-abuse tax (“BEAT”) to partnerships
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, FIN 48 determinations and IRS audits and controversy; as well as government attorneys who want to stay on top of what’s happening in the international tax arena.
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