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Join us for a two-day beginner to intermediate course with live group instruction on the international tax reporting requirements faced by U.S. shareholders regarding their foreign investments. This new hands on workshop has been designed to discuss the various forms (e.g. Form 5471, 8858, 8865) and the additional information that U.S. shareholders must disclose regarding their foreign subsidiary investments and cross border transactions (e.g. liquidations).
Benefits of Attending:
• Discuss the overall requirements of the various U.S. outbound international tax forms
(e.g. Forms 5471, 8858, 8865) required of U.S. shareholders for their foreign investments
• Understand the calculation and signifi cance of the amounts contained in calculating a
corporation’s foreign tax credit form (Form 1118)
• Explain the proper reporting of cross border transactions (e.g. Form 5471 Schedule O, Form 926)
and the relevance of the white paper disclosure of transactions required under IRC Section 6038B
• And more!
All paid attendees will receive the Bloomberg BNA Portfolio:
#947: Reporting Requirements Under the Code for International Transactions (a $400 value)
*One Portfolio per paid attendee. Quantities are limited.
Bloomberg BNA has developed a hands-on workshop to provide U.S. outbound international tax practitioners with training to thoroughly comply with the reporting of foreign earnings set forth in the IRS forms 5471, 8865, and 8858, as well as the foreign tax credit information set forth on the Form 1118. As the number of foreign entities owned by U.S. multinationals has increased so has the IRS scrutiny of the reporting of the earnings information of those entities. The nature of the reporting is oftentimes very complex and therefore the need to adequately understand the forms and their requirements is very important. This course uses a hands-on approach, directly working with the forms, to focus exclusively on the issues contained in properly reporting the identifying information, the foreign entity income statement, balance sheet, E&P adjustments, etc. In addition, the course discusses the various reporting requirements for cross border transactions (e.g. Form 926, Form 5471 Schedule O).
This course is an introductory course regarding the preparation and review of the U.S. international tax compliance forms. This program is transitional which is appropriate for newly admitted attorneys. This program is designed for VPs of tax and accounting, corporate tax directors, corporate tax managers, tax accounting managers and supervisors, and tax professionals who work in the area of international tax compliance.
8:00 AM Registration and Continental Breakfast
8:30 AM Introduction and Overview of International Compliance Tax Forms
• Overview of Forms 5471, 8858, and 8865 and general filing requirements
• Categories of filers
• Penalties for non-filing
• Procedure for “dormant” filing
• Review of applicable foreign exchange rate requirements
10:15 AM Break for Refreshments
10:30 AM Form 5471
• Review of overall requirements for income statement and balance sheet
• Earnings and profits adjustments and tracking (Schedules H and J)
• Identification and calculation of Subpart F and S. 956 income inclusions (Schedule I)
• Reporting of intercompany transactions (Schedule M)
12:15 PM Luncheon
1:15 PM Form 8858
• Overall methodology for completion of the form
• Identification of tax owners of foreign disregarded entities
• Review of methodologies for calculating the income of a foreign branch
• Overview discussion of the foreign exchange gain or loss calculation
2:45 PM Break for Refreshments
3:00 PM Form 8865
• Overview of the reporting requirements for foreign partnerships: income statement, balance sheet and separately stated items
• Identification of trade or business and other income items (e.g. capital gains and losses)
• Review of separately stated income / deduction items in Form 8865, Schedule K-1
5:30 PM Conference Adjourns for the Day
8:00 AM Continental Breakfast
8:30 AM Foreign Tax Credit – Form 1118
• Overview of foreign tax credit calculations
• Reporting of interest and R&D apportionment disclosure
• Reporting of separate baskets and foreign tax credit limitation
• Flow through of dividends from lower tier subsidiaries
10:30 AM Break for Refreshments
10:45 AM Reporting of Transactions
• Requirements for reporting of cross border transactions, e.g. liquidations, reorganizations
• Discussion of the required Form 5471, Schedule O disclosure of the type and nature of the transaction
• Review of the applicable S 367 disclosure regarding the carryover of tax attributes, e.g. E&P, following a reorganization transaction
12:30 PM Luncheon
1:30 PM Continued Discussion of Transactions Involving Schedules O and P
• Review of transactions invoking contributions to corporations and partnerships and the required disclosure on Schedules O and P of the Forms 5471 and 8865
• Discussion of information required on Form 926 and review of additional white paper disclosure required under IRC Sections 6038B and 6046A
3:00 PM Wrap Up / Question and Answer Session
3:15 PM Conference Concludes
Times/topics/speakers subject to change.
©2015 The Bureau of National Affairs, Inc. All rights reserved.
November 30 - December 1, 2016
AMA Conference Center
1601 Broadway (at 48th and Broadway)
New York, NY 10019
Hotel accommodations are at your own discretion. We suggest the following:
319 West 48th Street
New York, NY 10036
Tel: (212) 245-7000
Novotel of New York
226 West 52nd Street
New York, NY 10019
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 firstname.lastname@example.org 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.
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Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.
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