Intermediate U.S. International Tax Update - Raleigh

Raleigh, NC

Price: $1595

Year-End Tax Pass

Fulfill all of your remaining CPE/CLE credits with entry to an unlimited number of upcoming Bloomberg BNA tax seminars and webinars in 2016 for less than the price of two seminars.

Click here to learn more and purchase your pass!



A two and one-half day intermediate level course with live group instruction on the latest U.S. international tax issues facing multinationals doing business overseas.


After attending this event, participants will be able to:  

  • Discuss disclosure of uncertain tax positions
  • Determine the most tax-efficient vehicles for investing overseas
  • Understand how foreign exchange gain (loss) is computed for cross-border operations
  • Discuss U.S. tax recapture consequences of a dual consolidated or branch loss and an overall foreign or domestic loss
  • Understand the latest IRS rules under Sec. 987 for taxing payments between foreign corporate disregarded entities
  • Explain how to compute foreign tax credit benefits for separate basket income using look-through rules
  • Describe the latest interest and R&D expense apportionment rules for foreign tax credit and domestic production activities
  • Understand the latest changes to the Subpart F branch rules and investments in U.S. property
  • Plan for the migration of intangibles and implementing a cost-sharing agreement under the latest IRS regulations
  • Ascertain how a cross-border merger or acquisition can trigger gain recognition and affect future distributions from the foreign target
  • Determine the U.S. tax consequences of selling CFC shares under the Sec. 1248 recharacterization rules  

All paid attendees will receive the Bloomberg BNA Portfolio: 
Outbound Tax Planning for U.S. Multinational Corporations (Portfolio #6380)
*One Portfolio per paid attendee. Quantities are limited.


This seminar with live group instruction is intended for corporate tax directors and managers, accountants and CPAs, attorneys, and other corporate finance executives looking for practical solutions to complex cross-border tax issues. This program is nontransitional which is appropriate for experienced attorneys.


An introductory course or its equivalent is recommended prior to attending the program.




8:30 am  Registration & Continental Breakfast


9:00 am  Doing Business Overseas, Choice of Entities & Overlay of Treaties

Sean King, Align Global Consulting, Raleigh, NC

Doing Business Abroad in Branch or Partnership Form

9:45 am  International Joint Venture & Partnerships                              
Oscar Grisales-Racini, Grisales-Racini-Shefer LLLP, Aventura, FL

11:00 am Coffee Break

11:15 am Dual Consolidated Losses                    
Oscar Grisales-Racini, Grisales-Racini-Shefer LLLP, Aventura, FL

12:15 pm Luncheon

Doing Business Abroad in Corporate Form

1:00 pm Outbound Asset Transfers to a Foreign Corporation – Section 367(a) and Section 367(d)
Sean King, Align Global Consulting, Raleigh, NC

2:15 pm    Coffee Break
2:30 pm Dispositions of Controlled Foreign Corporation Stock – Section 1248
Sean King, Align Global Consulting, Raleigh, NC          

3:45 pm International Mergers & Acquisitions
Sean King, Align Global Consulting, Raleigh, NC

5:00 pm    Seminar Concludes


Foreign Tax Credits

8:15 am  Continental Breakfast

8:45 am  Direct Foreign Tax Credits
Jennifer Molnar, Baker & McKenzie LLP, Washington, DC

9:45 am    Coffee Break

10:00 am Section 904 Limitations
Jennifer Molnar, Baker & McKenzie LLP, Washington, DC

11:00 am GST / VAT Forcing its Way on the International Agenda for U.S. Corporates
David Tuomey, Orsa Sawai, Richmond, Surrey, England

12:00 pm Luncheon

Subpart F

1:00 pm  Subpart F – General Overview and Section 959
Rob Clary, McDermott Will & Emery LLP, Chicago, IL

2:15 pm  Foreign Base Company Income – Section 954
Rob Clary, McDermott Will & Emery LLP, Chicago, IL

3:30 pm Coffee Break

3:45 pm  Section 956 Investments in United States Property

Rob Clary, McDermott Will & Emery LLP, Chicago, IL

5:00 pm    Meeting Adjourns for the Day


7:45 am  Continental Breakfast

Transfer Pricing

8:15 am Overview BEPS Final Reports including Transfer Pricing Actions
David Bowen, Grant Thornton LLP, Washington, DC    

9:15 am Conducting a BEPS Risk Assessment
David Bowen, Grant Thornton LLP, Washington, DC

9:45 am  Transfer Pricing for Services
David Bowen, Grant Thornton LLP, Washington, DC    

10:15 am Coffee Break

10:30 am Country-by-Country Reporting
David Bowen, Grant Thornton LLP, Washington, DC

11:00 am Resolving Transfer Pricing Controversies
David Bowen, Grant Thornton LLP, Washington, DC

12:00 pm Competent Authority and Advance Pricing Agreements
David Bowen, Grant Thornton LLP, Washington, DC

12:30 pm Seminar Concludes



November 2-4, 2016

Renaissance Raleigh North Hills Hotel
4100 Main at North Mills St    
Raleigh, NC 27609

A limited number of rooms are available at the reduced rate of $185 per night. Please click here to reserve your room today. The last day to book your room at this reduced rate is 10/10/2016.



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 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 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, complaints and cancellations, please contact us at 800.372.1033, or e-mail


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

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.


Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.