See Credit Details Below
Overview
Why You Should Attend
The past several years have seen both national and global pushes to further tax cross-border income. While the new norm of minimum tax regimes may seem innocuous, they can easily lead to double taxation. In order to avoid such perils, it is critical to understand the U.S. cross-border rules. The 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.
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”) and the recently enacted Inflation Reduction Act (“IRA”), as well as consider the impact of Pillar 2. 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.
What You Will Learn
After completing this program, participants will be able to:
- Calculate base erosion anti-abuse tax (“BEAT”) and modified taxable income (“MTI”)
- Interpret recent OECD policy developments affecting transfer pricing
- Identify recent changes to the anti-deferral rules, foreign tax credits and domestic incentives
- Spot areas where the risk of double taxation may be high
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