Tax professionals need to maintain their knowledge of the latest Subpart F rules and understand how deemed dividends under Subpart F and Sec. 956 investments can be used as a tax planning tool. This course – only offered by Bloomberg BNA – is designed as an intensive, technical review of the Subpart F provisions and their affect on U.S. multinational planning.

Course Level: Technical Review Delivery Method: Live Group

LEARNING OBJECTIVES

After attending this event, participants will be able to
• Discuss subpart F provisions
• Describe foreign base company sales income
• Explain how to calculate Sec. 1248 amounts
• Describe the interaction between Subpart F and Subchapter K provisions
• List issues involved with reporting for disregarded entities and allocation of deductions
• AND more!
 

All paid attendees will receive the Bloomberg BNA Portfolio: Foreign Base Company Income(Other than FPHCI), #928 3rd
*One Portfolio per paid attendee. Quantities are limited.

PREREQUISITES

There are no prerequisites for attending this program.

SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS

If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution.

To request a transfer, contact customercare@bna.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event. Cancellations must be made in writing to customercare@bna.com more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event.

For more information regarding administrative policies, such as complaints and cancellations, please contact us at 800.372.1033, or e-mail customercare@bna.com.

 

Morgan Lewis Conference Center
101 Park Ave #40
New York, NY 10178
Tel: 212-309-6801

Hotel accommodations are at your own discretion.
We suggest the following:

New York Helmsley: Tel: 212.490.8900
212 East 42nd St, New York, NY

Grand Hyatt: Tel: 212.883.1234
109 East 42nd St., New York, NY

DAY ONE

8:00 AM Registration and Continental Breakfast

8:45 AM Chairperson’s Introduction and Overview

9:00 AM Overview of Subpart F Provisions – Basic Mechanics
• What is a Controlled Foreign Corporation?
• Effect of voting agreements, etc. on CFC determination
• Basic mechanics of Subpart F
• Overview of Subpart F income definition
• Exceptions to Subpart F income definition, including the E&P limitation, de minimis exception, full inclusion rule, and high-tax exception
• Calculating the Sec. 960 credit for deemed inclusions
• Introduction to previously taxed income accounts

10:30 AM Break for Refreshments

10:45 AM Sec. 954(d) - Foreign Base Company Sales Income
• Review of the foreign base company sales income rules of Sec. 954(d)
• Consideration of the IRS’s recent attack on the “its” defense
• Review of the application of the Branch Rule of Sec. 954(d)(2)
• Consider the development of the IRS’s response to contract manufacturing structures
• Detailed review and analysis of the newly proposed manufacturing regulations

12:15 PM Luncheon

1:15 PM Overview of Secs 954(c) and 954(e)
• Detailed review of foreign personal holding company income definition
• Calculating foreign base company services income and application of the substantial assistance rules
• Review of the foreign base company service rules
• Consideration of the application of foreign base company services rules to check-the-box subsidiaries
• Preparing for sunset of CFC look-through

2:30 PM Break for Refreshments

2:45 PM Sec. 1248
• Overview of Sec. 1248 and calculation of the Sec. 1248 amount
• Foreign tax credit consequences of recognizing Sec. 1248 amount, interaction with Secs 338(g) and 338(h)(16), discussion of CCA 200103031
• Planning for dispositions of CFC stock
• Proposed check-the-box anti-abuse regulations
• Discussion of the so-called “check and sell” technique for sales of first-tier and lower-tier CFCs

4:00 PM Interaction of Subpart F and Subchapter K Provisions
• Using foreign partnerships v. corporations in joint venture planning
• The Tax Court and Eighth Circuit decisions in Brown Group v. Commissioner
• Discussion of final Brown Group regulations
• Developments resulting from the American Job Creation Act
• Domestic Subpart F “blocker” partnerships and Notice 2009-7

5:30 PM Meeting Adjourns for the Day

DAY TWO

8:00 AM Continental Breakfast

8:30 AM Reporting Issues for Disregarded Entities and Allocation of Deductions in Computing Subpart F Income
• Form 8858
• Potential increased audit risk for transactions between disregarded entities
• Calculating net foreign base company sales income
• Computation of CFC’s E&P for purposes of the E&P limitation
• Use of accumulated E&P deficits and E&P deficits of lower-tier CFCs to reduce Subpart F income

9:45 AM Break for Refreshments

10:00 AM Sec. 956 - CFC Investments in United States Property
• Overview of Sec. 956 and mechanics of deemed income inclusion
• Co-ordination of Sec. 956 inclusions and Subpart F inclusions
• Definition of “United States Property”
• Application of Notice 2008-91 and discussion of issues in AM2009-013
• Issues involving Sec. 956 and partnerships

11:15 AM Sec. 959 – Previously Taxed Income of a CFC
• Review of the PTI provisions of Sec. 959
• Proposed Sec. 959 regulations
• Analysis of the foreign currency implications of PTI distributions
• Consideration of PTI planning techniques

12:30 PM Luncheon

1:15 PM Repatriating Low-Tax Earnings from a CFC
• Affirmative use of Sec. 956
• Review of Notice 2006-85 and 2007-48, and the “Killer B “ temporary regulations
• Analysis of proposed stock basis regulations and temporary Sec. 367[a] regulations addressing repatriation via Sec. 304 transactions
• Discussion of alternatives to permanent repatriation of low-taxed income

3:00 PM Conference Concludes


Times/topics/speakers subject to change

Copyright Bloomberg BNA 2013

EDUCATIONAL COURSE CREDIT

UP TO 15 CPE CREDIT HOURS AVAILABLE

Bloomberg BNA is registered with the National Association of the State Boards of Accountancy as a sponsor of continuing professional education on the National Registry of CPE sponsors. State Boards of Accountancy have final authority on the acceptance of individual courses. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417.

UP TO 15 CLE CREDIT HOURS AVAILABLE

Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at 800.372.1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com .

HARDSHIP POLICY

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 accreditations@bna.com. Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.