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Introduction to US International Tax for Non-International Tax Professionals



Wednesday, March 27, 2013
Product Code - TMW76
Speaker(s): Douglas S. Stransky, Sullivan & Worcester LLP
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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 the U.S. international tax rules.

This presentation is designed for non-international tax professionals with little or no international tax experience. The presentation focuses on the U.S. tax issues that those seeking to expand internationally will face. 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.

The objectives of this live webinar include providing participants with a conceptual understanding and practical application of the following:

  • International Tax Overview
    • Taxation of U.S. Persons with Foreign Income
    • Taxation of Foreign Persons with U.S. Income
  • Structuring Foreign Operations
    • Forms of Doing Business, Including “Check-The-Box” Planning
    • Foreign Income Tax Exposure
    • Tax Implications of Creating Foreign Entities or Transferring Assets Outside the U.S.
  • Foreign Tax Credits
    • Direct and Indirect Credit
    • When to Claim the Tax Credit
    • Overview of Foreign Tax Credit Baskets and Limitation
  • Controlled Foreign Corporations
    • Anti-Deferral Regime, e.g., Subpart F
    • Code section 956
    • Previously Taxed Income
    • Key Reporting Requirements
  • Planning Opportunities

Educational Objectives

Upon completion of this program, participants will:

  • Be aware of international tax issues facing U.S. based multinationals in cross-border transactions, with particular emphasis on forms of doing business and tax implications of creating foreign entities or transferring assets outside the U.S.;
  • Be familiar with the controlled foreign corporation regime and foreign tax credit rules; and
  • Recognize international tax planning opportunities that can add value to your company (or to your clients’ companies).

Course Level: Basic
Course Prerequisites: None
Delivery method: Group Interact Live
Credits Available 1.5 

Douglas S. Stransky, Sullivan & Worcester LLP

Douglas S. Stransky is a U.S. 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 a former 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, a frequent speaker and author on numerous topics related to U.S. international tax, a member of the adjunct faculty at the Boston University School of Law, and is listed in Best Lawyers in America. 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, the U.S. Tax Court and the U.S. District Court, District of Massachusetts.