Product Description

Why You Should Attend
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.
 
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 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

 
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

Agenda & Materials

• 9:00 AM EST

  Opening Remarks
• 9:10 AM EST

  Inbound Planning and Developments

  • Section 163(j) as applied to inbound investment • New anti-hybrid rules • BEAT as applied to inbound investment • Section 897(l) and Qualified Foreign Pension Funds • Treaty developments – U.S. Model Treaty and new treaty negotiations
• 10:15 AM EST

  Developments on Transfer Pricing

  • Impact of statutory changes to Sections 367 and 482 • Interaction of transfer pricing with BEAT, FDII and GILTI • Recent U.S. transfer pricing cases • BEPS and OECD developments affecting transfer pricing
• 11:15 AM EST

  Networking Break
• 11:30 AM EST

  Cross-Border M&A Planning and Developments

  • M&A aspects of Section 965 and Section 245A • Previously taxed income (“PTI”) issues in M&A transactions • TCJA changes to Section 367 and the Section 367 regulations (M&A aspects) • Changes to attribution rules and 30-day rule for controlled foreign corporations (“CFCs”) • Deletion of Section 958(b)(4) • Acquisitions of foreign targets • Acquisition of U.S. targets with foreign subsidiaries
• 1:00 PM EST

  Lunch
• 2:00 PM EST

  Foreign Tax Credits and Subpart F Planning and Developments

  • GILTI (Section 951A) and other changes to Subpart F • Section 245A and the repeal of Section 902 • Changes to interest expense apportionment and sourcing rules • Deletion of Section 958(b)(4) • Section 956 – pitfalls, planning and the new regulations • BEAT considerations for supply chains of U.S. multinationals
• 3:30 PM EST

  Networking Break
• 3:45 PM EST

  Cross-Border Partnership Planning and Developments

  • Inbound investment through partnerships – including U.S. trade or business issues • Territorial planning for pass-through structures (i.e., use of blockers) • Revised Section 163(j) as applied to partnerships • Income sourcing issues • Loans to foreign partnerships • Joint venture arrangements through partnerships
• 5:00 PM EST

  Adjourn

Please Note

MCLE webcasts are delivered completely online, underscoring their convenience and appeal. There are no published print materials. All written materials are available electronically only. They are posted 24 hours prior to the program and can be accessed, downloaded, or printed from your computer.