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This two-day technical session will focus on tax planning strategies to be used to reduce your company’s worldwide tax rate. This advanced level seminar will also examine the most up-to-date corporate tax developments that will affect your company’s bottom line.
Course Level: Technical Update Delivery Method: Live Group
By attending this event, attendees will be able to:
• Discuss CFC investments in U.S. property
• Learn key year-end tax, securities and exchange control filing/reporting and requirements outside the U.S.
• Review current trends in corporate inversions
• Understand Subpart F impacts of foreign currency gains and losses
• List arbitration and competent authority developments
• And more!
WHY YOU SHOULD ATTEND
Changes in U.S. and foreign laws, recent court decisions, and tax rulings can have a major impact on the tax cost of doing business abroad. Highlights will include recent foreign tax credit and transfer pricing regulations, strategies for repatriating foreign earnings, Subpart F, and earnings and profits issues. Also being covered is FATCA, Sec. 199, currency transactions, tax treaties, and mergers and acquisitions issues including reorganizations.
WHO SHOULD ATTEND
This program is designed for VP taxes, corporate tax directors, attorneys, tax managers, accountants, corporate controllers, treasurers and CFO, lawyers and tax council. This program with live group instruction is transitional which is appropriate for newly admitted attorneys. There are no prerequisites for attending this program.
8:30 AM Registration & Continental Breakfast
9:00 AM Welcome and Overview
9:15 AM Section 199
• Review of IRS guidelines
• Practical considerations associated with implementation
• Current trends and risks
10:15 AM Subpart F Planning
• Repatriating low tax earnings from a CFC
• CFC investments in U.S. property
• Section 1248 consequences of disposition of CFC stock
• Foreign tax credit considerations for Subpart F income
11:15 AM Break for Refreshments
11:30 AM FATCA
• On board in plain english
• Compliance sanity check
• What your foreign affiliates need to to do to avoid 30% withholding and how to help them
12:30 PM Luncheon
1:30 PM Transfer Pricing Update
• IRS roadmap – audit trends
• Marketing intangibles
• Current proposals and impact on BEPS
• Transfer pricing documentation
2:30 PM Inversions, Repatriations and Other Advanced Cross Border M&A Transactions
• Current trends in corporate inversions
• Intragroup repatriation transactions
• Final regulations on outbound cross-border asset reorganizations
• Notice 2012-39 and its progeny
3:30 PM Break for Refreshments
3:45 PM Merger and Acquisitions Issues Including Reorganizations
• Tax free organizations under Sections 368, 355 and 332
• Taxable transactions under Section 367
• Due diligence considerations in cross border transactions
• Strategic planning opportunities
4:55 PM Question & Answer Session
5:15 PM Seminar Adjourns for the Day
8:30 AM Continental Breakfast
9:00 AM End of the Year Wrap Up by Baker & McKenzie’s Foreign Legal Team
• Panel discussion
10:15 AM International Tax Aspects of Currency Transactions
• Sec. 986 – transactions issues including elections
• Sec. 987 – explanation of new proposed Sec. 987 regulations
• Subpart F impacts of foreign currency gains and losses
11:15 AM Break for Refreshments
11:30 AM Stock Option, Planning and Considerations
• Key year-end tax, securities and exchange control filing/reporting and requirements outside the U.S.
• Planning for 2017 annual grants – key regulatory changes
• Action items for complying with IRC Sec. 409A, e.g., timing of deferral elections
• IRC Sec. 162(m) planning issues
12:30 PM Luncheon
1:30 PM Earnings and Profits Documentation Planning
• Impact of accounting methods in E&P
• Timing of recognition of income and expense deferred options
• Adopting and changing methods
2:30 PM Tax Treaties – Current Thoughts and Considerations
• Partnerships and hybrid entities – entitlement to treaty benefits
• Treaty eligibility benefits for items of income rather than person
• Arbitration and competent authority developments
• U.S. taxation of foreign corporations’ business profits: and other code and treaty developments
3:30 PM Seminar Concludes
December 6 & 7, 2016
Baker & McKenzie
452 5th Avenue
New York, NY 10018
Hotel accommodations are at your own discretion. We suggest the following:
The Bryant Park Hotel
40 West 40th Street, New York, NY 10018
Grand Hyatt New York
109 E 42nd St, New York, NY 10017
70 Park Avenue Hotel
70 Park Avenue, New York, NY
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Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at firstname.lastname@example.org.
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Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.
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