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 Inflation Reduction Act (“IRA”), as well as consider the impact of Pillar Two. 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
Industries
Please note that the views and opinions expressed in this program represent those of individual speakers and do not necessarily reflect the views or positions of PLI.
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Credit Details
Credit Details For All Jurisdictions For This Program
| Jurisdiction | Status | Total | Credit Details |
|---|
Inbound Planning and Developments
Quyen P. Huynh, Jennifer Lee, Oren Penn, Robert H. Scarborough1:11:38This panel will discuss the latest developments affecting inbound planning. After completing this session, participants will be able to:
- Determine the applicability of the corporate alternative minimum tax (“CAMT”)
- Conduct domestically-controlled REIT analysis taking into account the latest proposed regulations
- Identify the latest developments in qualified foreign pension fund (“QFPF”) and Section 892 exemptions
- Assess the status of U.S. income tax treaties
- Apply the share buyback excise tax rules to repurchases involving non-U.S. publicly traded corporations
Quyen P. Huynh, Jennifer Lee, Oren Penn, Robert H. Scarborough III
Developments on Transfer Pricing
Komal Dhall, Rocco V. Femia, Brad McCormack0:56:33This session will explore recent transfer pricing developments, including guidance and transfer pricing controversy. After completing this session, participants will be able to:
- Evaluate the impact of recent guidance on intercompany financing arrangements and other items
- Understand the significance of recent and pending U.S. transfer pricing cases
- Interpret recent OECD policy developments affecting transfer pricing, including with respect to Amount B
- Understand the interaction between transfer pricing and minimum taxes, including the U.S. CAMT and Pillar Two top-up taxes
Komal Dhall, Rocco V. Femia, Brad McCormack
Cross-Border M&A Planning and Developments
Devon M. Bodoh, Tijana J. Dvornic, Laura Williams1:32:43This discussion will focus on the impact of recent U.S. tax law changes on global transaction planning. After completing this session, participants will be able to:
- Identify previously taxed earning & profits (“PTEP”) issues in M&A transactions
- Recognize the numerous technical rules that can result in deemed acquisitions and inflate domestic corporation shareholder’s ownership percentage, causing Section 7874 to apply in very unintuitive ways
Devon M. Bodoh, Tijana J. Dvornic, Elena M. Madaj, Laura Williams
Foreign Tax Credits (“FTCs”) and Subpart F Planning and Developments
Stephen R.A. Bates, Le Chen, Ronald A. Dabrowski, Elizabeth Sani Nelson, Amanda Pedvin Varma1:30:48This panel will explore the latest changes to the foreign tax credit regulations and the latest anti-deferral developments. After completing this session, participants will be able to:
- Identify situations where a foreign tax will be treated as creditable for U.S. purposes
- Distinguish between the activities-based test, source-based test and disposition of property test for attribution purposes
- Understand the changes in the definitions of a remittance and a contribution
Stephen R.A. Bates, Le Chen (Invited), Ronald A. Dabrowski, Elizabeth Sani Nelson, Amanda Pedvin Varma
Cross-Border Partnership Planning and Developments
Ari Berk, Kimberly S. Blanchard, Erin Cleary, Daren J. Gottlieb1:16:21This session will present an overview of the planning considerations affecting cross- border partnerships. After completing this session, participants will be able to:
- Determine pro rata share for controlled foreign corporation (“CFC”) income purposes
- Apply Sections 1248 and 751 in the partnership context
- Calculate a partner’s distributive share of base erosion tax benefits
Ari Berk, Kimberly S. Blanchard, Erin Cleary, Daren J. Gottlieb
