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.

Course Level: intermediate; Delivery method: group live

Learning objectives

After attending this event, participants will be able to

• Describe how the 2010 Obama tax legislation can affect international tax planning at your company in 2011
• 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
• NEW TOPIC ADDED!   Discuss Disclosure of Uncertain Tax Positions

Register for both the Introduction and the Intermediate Courses in the same location and Save up to $340!
Please call customer service at 1.800.372.1033, option 6 to take advantage of this offer.  

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".

EDUCATIONAL COURSE CREDIT

Up To 20 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 20 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.