A two day intermediate to advanced level conference with live group instruction providing an in-depth analysis of the many tax issues related to the formation and operation of an international joint venture. Structural planning ideas to transfers of intangibles and maximization of foreign tax credits, tax treaty issues and recent IRS rulings and positions will be discussed.
Course Level: Intermediate Delivery Method: Live Group
After attending this event, participants will be able to:• Describe dual consolidated losses• Explain section 752 recapture• Discuss how to maximize foreign tax credit benefits• List issues structured planning ideas• Identify Subpart F Issues• Discuss foreign partners filing U.S. federal income tax returnsAnd More!All paid attendees will receive the Bloomberg BNA Portfolio: Partners and Partnerships – International Tax Aspects Portfolio #910-2nd*One Portfolio per paid attendee. Quantities are limited.
There are no prerequisites for attending this program.
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.
MONDAY, NOVEMBER 18TH
Joint Venture Structuring Issues • Foreign Tax Credit Maximization• Partnership Agreement & Partnership Tax Elections• Deferral Options
Transfer of Property to an International Joint Venture • Section 367(a) Issues• Section 367(d) Issues• Partnership Rules Section 721
Doing Business with the Joint Ventures Intercompany Pricing Rules of Section 482 • Negotiating pricing arrangements between Partner & Partnership
Loss Recapture Rules • Section 1503 (d) Issues• Dual Consolidated Loss Rules• Section 367 Branch Loss recapture rules• Section 904(f) Issues
Special Issues Regarding the Partnership Form • Currency Issues Section 987• Dual Consolidated Losses• Section 752 Recapture• Allocation of Expenses
Nonentity Alliance TUESDAY, NOVEMBER 19TH
CFC Partners in International Joint Ventures - Subpart F Issues • Anti Brown Group Regulations• Special Issues in Foreign Base Company Sales Income• Section 956 Issues
Partnership with US & Foreign Partners Conducting Business Inside the US
• Section 1446 Withholding Issues• Foreign Partners Filing US Federal Income Tax Return• Sale or Exchange of Partnership Interest
State & Local Tax Considerations
Data Management & Related Reporting Requirements for Joint Venture
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.
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 .
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.