Bloomberg BNA Conference Provides Multinational Companies with Tools to Plan for and Manage Complex International Tax Issues

Companies — and the practitioners that advise them — that fail to comply with international tax regulations risk jail, financial penalties, and loss of reputation and customers.  Bloomberg BNA | CITE will host a live conference, Intermediate U.S. International Tax Update, April 25-27 in New York, that will provide practical solutions to complex cross-border tax issues, including an in-depth look at U.S. foreign tax credit, Subpart F, and cross-border mergers and acquisition transactions.

Intended for corporate tax directors and managers, accountants and CPAs, attorneys, and other corporate finance executives with some  exposure to the subject, this conference will help attendees to identify key tax issues in cross-border acquisitions and the repatriation of income from overseas.

"This conference provides attendees with a complete look at evolving issues," notes Diane Pastore, Executive Director at Bloomberg BNA | CITE. "They'll learn about the latest interest and R&D expense apportionment rules for foreign tax credit and domestic production activities, and they'll examine the latest changes to the Subpart F branch rules and investments in U.S. property."

Attendees will also examine new cost-sharing rules, disclosure of uncertain tax positions, the transfer pricing controversy and competent authority, and transfer pricing on intercompany services and intangibles.

Sessions will address doing business abroad in branch, partnership, and corporate form; understanding the foreign currency rules; and identifying direct and indirect foreign tax credits and Section 904 limitations.

By attending the two-and-one-half-day conference, attendees will:

• Learn how the 2010 Obama tax legislation can affect international tax planning for companies in 2012
• Determine the most tax-efficient vehicles for investing overseas
• Understand how foreign exchange gain (loss) is computed for cross-border operations
• Discover U.S. tax recapture consequences of a dual consolidated or branch loss and an overall foreign or domestic loss
• Understand the latest IRS rules under Sec. 987 for taxing payments between foreign corporate disregarded entities
• Learn how to compute foreign tax credit benefits for separate basket income using look-through rules
• Learn how to plan for the migration of intangibles and implement a cost-sharing agreement under the latest IRS regulations
• Ascertain how a cross-border merger or acquisition can trigger gain recognition and affect future distributions from the foreign target
• Determine the U.S. tax consequences of selling CFC shares under the Sec. 1248 recharacterization rules

TheIntermediate U.S. International Tax Update will take place at the Morgan Lewis & Bockius Conference Center in New York, New York. To register, go to www.bna.com or call (914) 328.5656 for further information on special rates.