Basics of International Taxation 2023

Why You Should Attend

In a global business environment, transactions with customers and suppliers often transcend national borders, and investment and activities are frequently cross-border as well.   An understanding of the U.S. international tax rules, especially after enactment of the 2017 Tax Act, is of paramount importance to a wide variety of tax and corporate professionals.

This year’s program will be led by international tax experts and focuses on specific types of outbound and inbound investment and activities, and their U.S. tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the new U.S. tax rules address these issues. Special attention will be given to the ways the U.S. tax rules impact financings, mergers, acquisitions, and other commercial activities.

What You Will Learn

After completing this program, participants will be able to:

• Distinguish between situations where a U.S. investor should structure a foreign corporation to operate directly, and those where they should form a separate entity, under the changes made by the 2017 Tax Act
• Identify the types of expenses that can be allocated to gross income
• Apply foreign tax credit baskets to the foreign income of U.S. shareholders in a controlled foreign corporation (“CFC”)
• Recognize the impact of the sale of CFC stock on the repatriation of earnings of a foreign corporation
• Identify foreign corporations whose U.S. owners are not subject to U.S. tax until a dividend

Who Should Attend

Corporate, law firm and accounting firm professionals that consider cross-border transactions and need a working knowledge of relevant U.S. international tax rules, 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: Corporate, law firm and accounting firm professionals that consider cross-border transactions and need a working knowledge of relevant U.S. international tax rules, 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.

Advanced Preparation: None

Segments with an asterisk (*) are available only with the purchase of the entire program.

• Opening Remarks* [00:02:56]
  John L. Harrington, Corey M. Goodman
• Taxation of Foreign Income: U.S. Shareholders in Controlled Foreign Corporations (“CFCs”) [01:12:43]
  John D. Bates, Aliza Slansky, Anisa Afshar
• Taxation of Foreign Income: Non-CFCs [01:10:32]
  Richard Williams, Enrica Ma, Larry R. Pounders
• Considerations in Structuring Outbound Investments by U.S. Persons [00:56:32]
  Corey M. Goodman, Bradford E. LaBonte, Karen R. Li
• Compliance with Minimum Taxes [01:00:07]
  Shane J. Kiggen, Amy K. Chapman
• Source of Income, and Allocation and Apportionment of Expenses [01:01:14]
  Amanda Pedvin Varma, Caren S. Shein, Jeffrey P. Cowan
• Repatriating Earnings from a Foreign Corporation [01:10:05]
  Gary Scanlon, Elizabeth Sani Nelson, Brady Plastaras
• Tax Concerns of Foreign Persons Investing in the United States - Active Investments [01:30:13]
  James S.H. Null, Sarah E. Stein, Daniel J. Winnick
• Tax Concerns of Foreign Persons Investing in the United States - Funds and Passive Investments [01:14:46]
  Michele J. Alexander, Jeremy Naylor, Subin Seth
• Transfer Pricing [01:15:31]
  John P. Warner, Kathleen C. Arsenault
• Tax Treaties and Dispute Resolution [01:15:21]
  Elizabeth J. Stevens, Greg A. Texley, Melanie Godelis
• Foreign Tax Credit (“FTC”) Issues [01:15:13]
  Quyen P. Huynh, John L. Harrington, Teisha M. Ruggiero

The purchase price of this Web Program includes the following articles from the Course Handbook available online:

• Complete Course Handbook
• Deloitte Tax Alert, Treasury, IRS Release Proposed Foreign Tax Credit Regulations (November 18, 2022)
  John D. Bates
• EY Alert, No. 2022-1764, Proposed Foreign Tax Credit Regulations Offer Relief from Cost Recovery and Source-Based Attribution Rules and Include Other Key Changes (November 25, 2022)
  Enrica Ma
• Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception (August 5, 2022)
  Bradford E. LaBonte
• The Corporate Alternative Minimum Tax
  Shane J. Kiggen
• Limitation on Benefits: The U.S.-Croatia Tax Treaty and Potential Changes Ahead
  Amanda Pedvin Varma
• Repatriation Post-TCJA (April 21, 2023)
  Elizabeth Sani Nelson,Gary Scanlon
• POV on BEAT: Who Owns What?
  Kimberly Tax Majure
• Proskauer Alert, New Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’ US Real Estate Investments (January 13, 2023)
  Amanda H. Nussbaum,Carrie Slaton,David S. Miller,Jeremy Naylor,Muhyung (Aaron) Lee,Richard M. Corn
• Fundamentals of U.S. Transfer Pricing (April 26, 2023)
  Steven C. Wrappe
• The Intersection of Section 482 and Other International Tax Provisions (April 27, 2023)
  John P. Warner
• Overview of U.S. Tax Treaties (April 20, 2023)
  John L. Harrington
• Tax Treaty Interpretation and Conflicts with U.S. Federal Law (March 2, 2009)
  Edward Dennehy,Stephen Ehrlich
• Tax Treaties and Dispute Resolution (PowerPoint slides)
  Elizabeth J. Stevens,Greg A. Texley,Melanie Godelis
• Creditability of Foreign Taxes (April 20, 2023)
  John L. Harrington

Presentation Material

• Earning Income Through a Foreign Corporation
  John D. Bates, Aliza Slansky, Anisa Afshar
• Taxation of Foreign Income: Non-CFCs
  Enrica Ma, Richard Williams, Larry R. Pounders
• Considerations in Structuring Outbound Investments by U.S. Persons
  Corey M. Goodman, Bradford E. LaBonte, Karen R. Li
• Compliance with Minimum Taxes
  Amy K. Chapman, Shane J. Kiggen
• Sourcing of Income and Expenses
  Caren S. Shein, Amanda Pedvin Varma, Jeffrey P. Cowan
• Repatriation Post-TCJA
  Elizabeth Sani Nelson, Gary Scanlon, Brady Plastaras
• Foreign Persons Investing in the United States Active Business Investments
  Kimberly Tan Majure, James S.H. Null, Sarah E. Stein
• Foreign Persons Investing in the United States (Inbound Investments)
  Michele J. Alexander, Jeremy Naylor, Subin Seth
• U.S. Transfer Pricing Overview
  John P. Warner, Kathleen C. Arsenault
• Tax Treaties and Dispute Resolution
  Elizabeth J. Stevens, Melanie Godelis, Greg A. Texley
• Foreign Tax Credit Issues
  John L. Harrington, Quyen P. Huynh, Teisha M. Ruggiero

In a global business environment, transactions with customers and suppliers often transcend national borders, and investment and activities are frequently cross-border as well.   An understanding of the U.S. international tax rules, especially after enactment of the 2017 Tax Act, is of paramount importance to a wide variety of tax and corporate professionals.

This year’s program will be led by international tax experts and focuses on specific types of outbound and inbound investment and activities, and their U.S. tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the new U.S. tax rules address these issues. Special attention will be given to the ways the U.S. tax rules impact financings, mergers, acquisitions, and other commercial activities.

What You Will Learn

After completing this program, participants will be able to:

• Distinguish between situations where a U.S. investor should structure a foreign corporation to operate directly, and those where they should form a separate entity, under the changes made by the 2017 Tax Act
• Identify the types of expenses that can be allocated to gross income
• Apply foreign tax credit baskets to the foreign income of U.S. shareholders in a controlled foreign corporation (“CFC”)
• Recognize the impact of the sale of CFC stock on the repatriation of earnings of a foreign corporation
• Identify foreign corporations whose U.S. owners are not subject to U.S. tax until a dividend