Join us for a two day technical update with group live instruction featuring the latest tax planning strategies and opportunitis using the latest changes issued by the IRS in the the foreign currency area.

Course Level : update; Delivery Method: group live  

Learning Objectives:

After attending this event, participants will be able to

• Explain of the New Proposed Section 987 Regulations
• Discuss Special Issues for Hyperinflationary Currencies
• Describe application of ASC-740 to Foreign Branches
• List Subpart F & Impact of Foreign Currency Gains & Losses
• Identify translation Issues relating to Section 986
• Determine a taxpayers " functional currency" and Section 985
• List tax rules governing the hedging of FX risks

All paid attendees will receive the Bloomberg BNA Portfolio: #919 - 3rd U.S. to Foreign Transfers Under Section (367) a
*One Portfolio per paid attendee. Quantities are limited.

Prerequisites

There are no prerequisites for attending this program.

SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 800.372.1033, or e-mail customercare@bna.com . Credits will not be issued for "no shows".  

Monday, June 24, 2013

7:30am Registration and Continental Breakfast

9:00am Conceptual Underpinnings of U.S. Foreign Currency Tax Rules

9:30am Section 985 – Functional Currency Determinations

• Identification of taxpayers and qualified business units subject to foreign currency rules.
• Determining a taxpayer’s “functional currency.”
• Use of the U.S. dollar as a functional currency.

10:30am Break and Refreshments

10:45am Section 986 – Translation Issues

• Translation of foreign taxes; elections.
• Relationship of translation rules to E&P calculations.
• Special problems in the translation of tax basis.
• Explanation of how foreign currency gain or loss can be triggered in the context of PTI distributions.

12:00pm Luncheon

1:00pm Section 987 –Explanation of the New Proposed Section 987 Regulations

• General overview of § 987 and its relevance to Subpart J.
• Identification of § 987 QBUs.
• Review of deemed transfer rules.
• Calculation of § 987 gain/loss under the proposed regulations.

2:15pm Special Issues for Hyperinflationary Currencies

• When a QBU will be subject to the hyperinflationary rules
• Detailed review of the DASTM regulations

3:00pm Break and Refreshments

3:15pm Section 988 Transactions

• Identification of § 988 transactions.
• Taxation of § 988 transactions.
• Treatment of nonfunctional currency debt instruments.

4:30pm Meeting Adjourned

Tuesday, June 25, 2013

7:45am Continental Breakfast

8:30am FAS 52

• Background of FAS 52
• Determination of functional currency
• Application of ASC 740 to foreign branches
• Financial treatment of transaction gain
• Role of deferred tax assets and liabilities

9:30am Overview of Taxation of Hedging FX Risks & The Effect of Financial Accounting Rules on Them

• General explanation of hedging structures.
• Tax rules governing the hedging of FX risks.
• Review of applicable rules and discussion of practical application

11:00am Break and Refreshments

11:00am Subpart F- Impact of Foreign Currency Gains & Losses

• Regulatory Elections
• Business needs exception.
• FX Hedging

12:30pm Meeting Adjourned

EDUCATIONAL COURSE CREDIT

Up To 12 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 12 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 attorneys earning less than $50,000 per year. If an attorney wishes to take advantage of this option, he or she must contact Bloomberg BNA directly. For attorneys who are unemployed or earning less than $35,000 per year, a full discount off the price of the program will be awarded upon written proof of hardship. Attorneys earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program.  Any attorney working in the public service sector also qualifies for a special price. If you have further questions regarding the hardship policy or seek additional 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.