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The Latest U.S. International Tax Legislation: What You Need to Know About H.R. 1586


Tuesday, September 21, 2010
Product Code - TMAU73
Speaker(s): Cyndi Lafuente, Kevin Levingston, Kristeen Witt, Joseph Calianno, Alan W. Granwell
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Agenda

As part of the Education Jobs Act of 2010, H.R. 1586, Congress approved a number of significant international tax changes that have modified certain long standing tax legislation. This live webinar will discuss these changes and how they deal with the new legislation.

Attend this live webinar and discuss:

• Rules to Prevent Splitting Foreign Tax Credits from the Income to which they Relate

• Denial of Certain Foreign Tax Credits for Covered Asset Acquisitions (including Section 338(g) transactions)

• Limitation on the Amount of Foreign Taxes Deemed Paid with Respect to Section 956 (the “956 Hopscotch Rule”)

• Special Rule with respect to Certain Redemptions by Foreign Subsidiaries (targeting certain section 304 transactions)

• Modification of Affiliation Rules for Purposes of Rules for Allocating Interest Expense

• Termination of Special Rules for Interest and Dividends Received from Persons Meeting the 80% Foreign Business Requirements

• Limitation on the Extension of the Statute of Limitations for Failure to Notify the Secretary of Certain Foreign Transfers

The panel will include nationally recognized international tax experts Alan Granwell, Partner at DLA Piper LLP and Joseph Calianno, Partner at Grant Thornton LLP, and more.

Educational Objectives:

By attending this webinar, practitioners:

• Will understand the foreign tax credit changes included in H.R. 1586, including the reasons for those changes;
 

• Will be familiar with the other changes included in H.R. 1586, including interest allocation, repeal of the 80/20 company rules, and the technical correction to the statute of limitations;
 

• Will understand the effective dates of these provisions, including grandfathering rules;

• Will be able to advise your clients on the implementation of these amendments.
 

Speakers

Cyndi Lafuente, Kevin Levingston, Kristeen Witt, Joseph Calianno, Alan W. Granwell

Cynthia B. Lafuente serves as Legislation Counsel, Joint Committee on Taxation, United States Congress. In her role, Cyndi serves as a nonpartisan tax resource to Congress on international tax matters. In this role, Cyndi provides counsel to the tax writing staffs of the House Ways & Means and Senate Finance Committees, the Senate Foreign Relations Committee, and individual Members of Congress on legislative proposals, international tax developments and treaties. Prior to joining JCT, Cyndi was the General Tax Counsel and Divisional Vice President, Tax Planning, for Abbott Laboratories, a $30 billion manufacturer of pharmaceutical, medical, and nutritional products based in the Chicago area.

Cyndi received a bachelor’s degree in history and economics from Duke University and a juris doctor degree from Chicago Kent College of Law. She has extensive practical experience in tax accounting matters, and completed the core accounting and audit program towards the DePaul University Master of Science in Accountancy degree. Her career in international tax has included positions with Arthur Andersen (Chicago, IL), AT&T / NCR (Dayton, OH), Andersen Consulting (now Accenture; Walnut Creek, CA) and Illinois Tool Works (Glenview, IL). In addition, she has both studied and lived in Madrid, Spain.

Recognition by former employers includes the Chairman’s Award, Abbott’s highest honor (for designing and leading the implementation of Abbott’s $4.3 billion section 965 repatriation) and NCR’s Annual Great Performance Award (Team), NCR’s highest honor (for her contributions to the international aspects of NCR’s spin-off from AT&T).

Cyndi is a member of the Tax Coalition’s Board of Directors and the International Fiscal Association/Midwest Steering Committee. She recently served on the Chicago Finance Exchange’s Board of Directors, and has been active in its financial literacy outreach program.

Kevin Levingston is a member of the legislative and policy staff of the Joint Committee on Taxation (“JCT”). The JCT is a nonpartisan committee of the United States Congress that operates to assist members of the majority and minority parties in both houses of Congress on tax legislation. Due to its non-partisan stature, it interacts with members of Congress, tax-writing committees and their staffs and ensures consistency on tax bills moving through the floor of each chamber, and to a House-Senate conference committee. Kevin focuses on international tax legislative matters.

Prior to joining the JCT in March 2009, Kevin was a Director with PricewaterhouseCoopers (PwC) in its Atlanta tax practice. While at PwC, Kevin assisted US and foreign multinational corporations with domestic and non-US tax planning, tax compliance, and income tax accounting related issues.

Kevin earned his Bachelor’s of Business Administration as well as his Masters in Accounting with a concentration in taxation from the University of Texas at Austin. He is a member of the Georgia Society of Certified Public Accountants and the American Institute of Certified Public Accountants.
 

Kristeen R. Witt is Legislation Counsel at the Joint Committee on Taxation. Ms. Witt joined the Joint Committee in 2008. Ms. Witt previously worked as the Tax Director for Zimmer Holdings, Inc.; as the Director of Domestic Tax Planning at Yum! Brands, Inc. (previously Tricon Global Restaurants, Inc.), and as a Tax Planning Manager at Coopers & Lybrand.

Joe Calianno is partner and the International Technical Tax Practice Leader in the National Tax Office of Grant Thornton LLP. He practices in all areas of international taxation and helps assist the offices around the firm and the firm’s clients with complex international issues. He regularly advises on issues relating to cross border restructuring and financing, subpart F, foreign tax credit planning, tax treaties and global tax rate reduction.

Prior to joining Grant Thornton LLP, Joe was a Special Counsel to the Deputy Associate Chief Counsel (International) in the office of Chief Counsel, Internal Revenue Service. As a Special Counsel, he was the technical advisor to the Associate and Deputy Associate Chief Counsel (International) and was involved in reviewing international regulations, revenue rulings, Notices, TAMs, PLRs and providing technical advice to the field. He also served as an Assistant Branch Chief in Branch 6 (Corporate) in the Office of Chief Counsel in which he reviewed corporate public guidance projects, PLRs and TAMs. Additionally, he was an Attorney-Advisor in Branch 4 (International) in the office of Chief Counsel.

Mr. Calianno also spent several years in private practice at the National Tax Office of a Global accounting firm and a large law firm in which he advised clients in several areas of tax law, including international, corporate and partnership taxation.

Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing multinational corporations and high-net worth individuals on cross-border transactions and controversies. He conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings, advising taxpayers on voluntary disclosures, assisting clients in obtaining regulatory changes and tax rulings and advising clients on tax legislation matters).

From 1981 through 1984, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs at the US Department of the Treasury. In that capacity, Mr. Granwell was the senior international tax advisor at the Treasury Department and was responsible for advising the Assistant Secretary for Tax Policy on legislation, regulations and administrative matters involving international taxation and directing the US tax treaty program.

Mr. Granwell has written numerous articles and has been a frequent lecturer on international tax matters.