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

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.

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 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.