Join us for a two-day intermediate to advanced level course with live group instruction on earnings and profits which is an important subject in your company's international planning and structuring.

Course Level: intermediate to advanced; Delivery Method: group live 

Learning Objectives

After attending this event, participants will be able to

• Provide Overview of Earnings & Profits
• List Earnings & Profits Details
• Determine Earnings & Profits of a Foreign Branch
• Discuss E&P and Subpart F Income
• Describe Repatriation Planning Cases, Rulings, and Other New E&P Developments
• List E&P After Spin-Offs, Mergers and Acquisitions
• Explain Earnings & Profits and Section 304 Transactions
• Manage E&P with Accounting Methods

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.

Day One

7:30 am Registration and Continental Breakfast

8:45 Welcome & Chairman Introduction

9:00 Overview of Earnings & Profits

• Determining Status of Distributions
   
• Subpart F Income Limitation
   
• Calculating Deemed Paid Foreign Tax Credits
   
• Section 898 Current & Proposed Rules
   
• Determining PFIC Inclusions
   
• Form 5471

10:15 Break for Refreshments

10:30 Earnings & Profits Details

• Elections Sections 964, 338
   
• Baskets [Current & Proposed Section 904 Rules]
   
• E&P Pools & Translating Foreign Taxes
   
• Converting to the Euro
   
• Effect of Deficits on Baskets & Pools
   
• Pre-1987 Losses Carried Over
   
• Post-1986 Losses Carried Back
   
• Inheriting E&P From a Merger or Liquidation
   
• Nimble Dividend Rule
   
• Discussion of Current & Proposed Section 902 rules
   
• Complex Section 902 Example

12:30 pm Luncheon

1:30 Determining Earnings & Profits When a Foreign Company Has a Branch

• Translating the Branch’s Income and Expenses Under Section 987
   
• Calculating the Exchange Gain or Loss
   
• On Branch Remittances and When the Branch is Terminated
   
• Check-the-Box Branch Issues
   
• Application of the Hybrid Branch Regulations

2:30 Earnings & Profits and Subpart F Income

• Example Illustrating the Recapture and Rebasketing of Profits After a Deficit Has Limited Subpart F Inclusions
   
• Nimble Dividend Rule Examples
   
• Examples of the Subpart F Branch Income Effective Tax Rate Calculations
   
• High Tax Exception Example Calculation
   
• Previously Taxed Income Focusing on:
• Own PTI
• Inherited PTI
• Acquired PTI
• Section 959 Ordering Rules
   
• Exchange Gain or Loss on Distribution of PTI Example Calculation

3:45 Break for Refreshments

4:00 Repatriation Planning

• Using Section 956 Affirmatively
   
• Moving Cash Via Section 304
   
• Reorganizations and Cash Movements
   
• Other Non-Dividend Repatriation Techniques

5:30 pm Question & Answer Session

5:45 pm Seminar Adjourns for the Day

Day Two

7:30 am Continental Breakfast

8:45 Cases, Rulings, and Other New E&P Developments

10:15 Break for Refreshments

10:30 Earnings & Profits After Spin-Offs, Mergers and Acquisitions

• Calculating E&P After a Section 355 Spin-Off
   
• Applying the Section 367(b) E&P Regulations to Reorganizations, Mergers and Acquisitions
   
• Planning Tips
   
• Example Calculations

12:00 pm Luncheon

1:00 Earnings & Profits and Section 304 Transactions

• When does Section 304 Apply
   
• Mechanics of Section 304
   
• Rev. Ruled 92 - 86
   
• Effect of E & P on Dividends
   
• Check the Box Issues

2:15 Managing E&P with Accounting Methods

• Impact of Accounting Methods on E & P
   
• Timing of Recognition of Income & Expense Deferral Options
   
• Adopting & Changing Methods

3:15 Question & Answer Session

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.