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Intermediate U.S. International Tax for Non-International Tax Professionals



Wednesday, November 16, 2011
Product Code - TMA56
Speaker(s): Douglas S. Stransky 
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As business becomes increasingly international at all levels, from the multinational to the sole proprietor, it is more likely than ever that your business (or your clients’ businesses) will need to understand international tax rules.

This presentation is designed for non-international tax professionals with some international tax experience. The presentation focuses on the U.S. tax issues that those seeking to expand internationally will face. This programs offers a more in-depth overview of international taxation than the basic “Introduction to U.S. International Tax for Non-International Tax Professionals” and is designed as either a stand alone program or a continuation of the introductory course.

Although U.S. individual taxation may be mentioned, this program emphasizes U.S. corporate taxation. Furthermore, U.S. income tax reporting and compliance requirements are only covered briefly.

Presentation Objectives:

The objectives of this 90 minute webinar include providing participants with a conceptual understanding and practical application of the following:
• Outbound Transfers under Code section 367
• The Foreign Tax Credit
• Sourcing Rules
• Expense Allocation and Apportionment
• Foreign Tax Credit Planning, e.g., increasing foreign source income
• Subpart F and PFIC Rules
• Branch Rules
• Subpart F Planning
• Code section 1248
• Code section 482 and Transfer Pricing Overview
• Tax Treaties and Code section 894
• Outbound Tax Planning

Upon completion of this program, participants will be able to:

• Have a deeper understanding of international tax issues facing U.S. based multinationals in cross-border transactions, with particular emphasis on Code section 367; the calculation of the foreign tax credit and planning ideas to maximum the ability to use the credit; planning to avoid subpart F inclusions; dispositions of controlled foreign corporations; transfer pricing; tax treaties and permanent establishment.
• Use tax planning ideas to address various issues that arise from U.S. multinational investing in foreign jurisdictions.

Douglas S. Stransky 

Douglas S. Stransky is an international tax partner in the Tax Department of the Boston office of Sullivan & Worcester LLP. Mr. Stransky concentrates his practice on international tax planning for multinational clients in the financial services, life sciences, manufacturing, private equity, technology and venture capital industries, with a particular emphasis on U.S.-based clients investing in foreign jurisdictions. He has advised a broad range of publicly traded and privately held multinational clients in structuring tax efficient international mergers, acquisitions, dispositions and reorganizations and designing cross border financing strategies and foreign holding company structures. He also assists companies with foreign tax credit utilization, foreign treasury and cash flow management, recapitalization of foreign operations to enhance foreign earnings repatriation efficiency and reduce foreign tax burdens. Mr. Stransky is the co-chair of the International Tax Committee of the Boston Bar Association, a member of the Board of Advisors for Practical U.S./International Tax Strategies and a frequent speaker at numerous international tax seminars. Prior to joining Sullivan & Worcester, Mr. Stransky was the Director of International Tax Services and a member of the National Outbound Team at PricewaterhouseCoopers LLP. Mr. Stransky holds a B.A. cum laude from Harvard University and a J.D. cum laude and LL.M. from the University of Miami School of Law. He is admitted to the Bar of the Commonwealth of Massachusetts.