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

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".

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 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.