International Tax Issues 2024 New York City

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

International Tax Issues 2024 New York City

Lecture Topics [Total time 00:07:00]

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

• Opening Remarks* [00:02:07]
• Michael A. DiFronzo
• Inbound Planning and Developments [01:10:18]
• Jennifer Lee, Quyen P. Huynh, Oren Penn, Kenneth A. Jeruchim
• Developments on Transfer Pricing [01:01:13]
• Thomas M. Zollo, Rocco V. Femia, Brad McCormack
• Cross-Border M&A Planning and Developments [01:32:15]
• Gregory R. Walker, Brady Plastaras, Devon M. Bodoh, Laura Williams
• Foreign Tax Credits (“FTCs”) and Subpart F Planning and Developments [01:32:09]
• Moshe A. Dlott, Amanda Pedvin Varma, Elizabeth Sani Nelson, Ronald A. Dabrowski, Stephen R.A. Bates
• Cross-Border Partnership Planning and Developments [01:15:48]
• Eric B. Sloan, Kenneth A. Jeruchim, Erin Cleary, Ari Berk

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

• Complete Course Handbook
• US Corporate AMT: Inbound Investors Beware of Aggregation Rules (November 15, 2023)
• Jonathan Rhein,Zaira Rivero,Jennifer Lee,Zachary Kling,Peter Glicklich
• Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties (March 22, 2023)
• Michael Lubetsky,Zachary Kling,Jennifer Lee,Peter Glicklich
• Section 1446(f)—The Confounding and Unavoidable U.S. Tax Withholding Regime That Applies to Nearly All Transfers of Partnership Interests (March 3, 2023)
• Jonathan Rhein,Zachary Kling,Jennifer Lee,Peter Glicklich
• U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023 (February 21, 2023)
• Jonathan Rhein,Peter Glicklich,Jennifer Lee,Zachary Kling
• Upcoming Proposed Regulatory Changes to Stock Buyback Excise Tax (December 29, 2022)
• Jonathan Rhein,Peter Glicklich,Zachary Kling,Jennifer Lee
• MAP: Past, Present, and Future
• Thomas Zollo
• Substance in Flux: DEMPE, BEPS 2.0, and COVID-19
• Mark Horowitz,Mark Martin,Thomas Bettge,Thomas Zollo
• The Blocked Income Problem in Transfer Pricing
• Mark Martin,Thomas Bettge,Thomas Zollo
• Managing Multilateral Controversy as Tax Authorities Crack Down on Transfer Pricing Enforcement
• Mark Horowitz,Theresa Kolish,Thomas Bettge,Addiesen Reboulet,Thomas Zollo,Cameron Taheri
• Killer Bs Get Stung—IRS Issues Proposed Rules Aimed at Triangular Reorganizations and Inbound Nonrecognition Transactions (December 1, 2023)
• Grant Solomon,Devon Bodoh
• Foreign Tax Credit Considerations After Notice 2023-55 (September 21, 2023)
• Amanda Varma
• Gibson Dunn, Client Alert, Tax Court Holds That Non-U.S. Fund Is Engaged in a U.S. Trade or Business (November 22, 2023)
• Eric Sloan

Presentation Material

• Inbound Planning & Developments
• Quyen P. Huynh, Jennifer Lee, Oren Penn, Kenneth A. Jeruchim
• Developments on Transfer Pricing
• Rocco V. Femia, Thomas M. Zollo, Brad McCormack
• Cross-Border Acquisitions
• Devon M. Bodoh, Gregory R. Walker, Laura Williams, Brady Plastaras
• Foreign Tax Credits and Subpart F Planning and Developments
• Stephen R.A. Bates, Ronald A. Dabrowski, Elizabeth Sani Nelson, Amanda Pedvin Varma, Moshe A. Dlott
• Cross-Border Partnership Planning and Developments
• Ari Berk, Erin Cleary, Eric B. Sloan, Kenneth A. Jeruchim