Agenda
As business becomes increasingly international at all levels, from the multinational to the sole proprietor, it is more likely than ever that your business will need to plan its tax strategy on an international basis. Due to the complex interplay between and among U.S. tax rules, non-U.S. tax rules and double-taxation treaties, properly integrated and cohesive tax planning is essential when business spans international borders.
This presentation focused on the U.S. tax issues that those seeking to expand internationally will face. Whether you have extensive international operations or are just beginning an international expansion, this audio discussion will present the common issues that must be addressed, including the common U.S. federal income tax compliance requirements.
Presentation Objectives:
The objectives of this 60-90 minute audio discussion included providing participants with a conceptual understanding and practical application of the following:
1. Selecting the form of foreign entity, including detailed discussion on the “check-the-box” regulations
2. Dual consolidation losses
3. Overall foreign losses
4. Branch loss recapture
5. Foreign currency transactions
Upon completion of this program, participants were able to:
1. Describe the framework for international tax planning
2. Recognize fundamental ideas and solutions available to plan for tax efficient foreign operations
3. Explain how check-the-box entities are valuable in planning to avoid Subpart F and other issues
4. Understand the impact on a change of entity classification on dual consolidated losses, overall foreign losses, and branch loss recapture
5. Recognize the various compliance requirements in international tax planning
Speakers
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, 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.