A two and one-half day technical update with live group instruction on the latest U.S. tax legislation and tax strategies for U.S. companies with operations overseas in 2013. 
  

Course Level : update; Delivery Method: group live 
  

BENEFITS OF ATTENDING

After attending this event, participants will be able to

• List how the latest legislative changes affect your company’s tax planning and compliance strategies in 2013
• Determine the latest tax benefits and non-benefits of using a hybrid entity overseas
• Describe the latest IRS regulations affecting the treatment of foreign exchange gain (loss) recognized by non-US branches and disregarded entities
• Explain how the foreign tax credit changes limit FTC benefits and affect FTC baskets and gross-up calculations
• Understand the latest expense apportionment rules for interest and R&D and how they can reduce foreign tax credit benefits
• List the latest Subpart F rules for foreign base company income and investments in US property and strategies for remitting dividends
• Ascertain how the latest US tax legislation limits FTC benefits in cross-border mergers and in Sec. 338 acquisitions
• Determine the 2013 US tax consequences under Sec. 1248 of CFC sales by U.S. companies and individuals
• Describe the 2013 US tax filing and compliance requirements for foreign entities and transactions
• Analyze the impact of the US transfer pricing rules on foreign profits of multinationals and evaluating IRS audit exposure in reporting uncertain tax positions

Prerequisites

There are no prerequisites for attending this program.

SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 800.372.1033, or e-mail customercare@bna.com . Credits will not be issued for "no shows".

San Francisco - Marriott Union Square
480 Sutter St
San Francisco, CA 94108
Tel: 866.912.0973

Limited Time Reduced Room Rate: $249.00 per night

Day One 
  

8:00 am Registration and Continental Breakfast  
  

8:45 am CITE Introduction and Overview 
  

9:00 am Reporting the Results of Foreign Operations and Activities

• What constitutes a controlled foreign corporation (CFC) and who is required to file Form 5471? – categories of filers
• Understanding the functional currency concept of QBUs – translation of income and B/S items, E&P and foreign taxes
• Preparing Form 5471 – analyzing the income statement and balance sheet for Subpart F and transfer pricing adjustments
• Tracking Earnings & Profits on Form 5471 for foreign dividend and gross-up calculations

10:30 am Break for Refreshments 
  

10:45 am Understanding the Rules for Computing Foreign Exchange Gain (Loss)

• Determining the character and source of Sec. 988 transactions
• Translation v. transaction gain (loss) – determining the functional currency for QBUs under Sec. 985
• Translation rules for foreign taxes and earnings and profits under Sec. 986
• Computing foreign exchange gain (loss) on remittances involving branches and foreign disregarded entities under Sec. 987

12:15 pm LUNCHEON  
  

1:30 pm Computing Direct and Indirect Foreign Tax Credit Benefits

• Obtaining foreign tax credit benefits for foreign withholding taxes – what constitutes a creditable income tax
• How the gross-up formula for foreign taxes is applied
• Computing the foreign tax credit limitation under Sec. 904
• Understand how to compute the separate foreign tax credit basket limitations in 2011 - separate limitation loss recapture
• Applying the related party look-through rules for dividend and interest payments between related CFCs and 10/50 entities

3:15 pm Break for Refreshments 
  

3:30 pm Expense Apportionment Update

• How expense apportionment can affect your ability to credit foreign taxes and deduct U.S. expenses
• Selecting the best apportionment method - gross-to-gross v. factual apportionment
• Understanding the new rules for interest apportionment – affect of exchange rates on foreign asset bases
• Strategies for minimizing the apportionment of research, state tax and S,G&A expenses to foreign source income

5:00 pm Meeting Adjourns for the Day  
  

8:00 am Continental Breakfast 
 

8:45 am How the Subpart F Anti-Tax Deferral Rules Operate

• Definition of U.S. shareholder - vote or value ownership
• Understanding the latest regulations involving Subpart F FPHC income - working with the branch rules for foreign sales and manufacturing activities
• Exceptions and limitations on application of the Subpart F rules
• Affirmative use of Subpart F - avoiding investments in U.S. property by first or lower-tier CFCs
• How new FTC limitations increase the US tax on dividends under Subpart F and Sec. 956

10:30 am Refreshment Break

10:45 am Interrelationship with the Tax Accounting Rules (ASC 740)

• Computing the tax provision v. tax liability for the year
• Analyzing deferred foreign taxes – applying the rules for permanently reinvested foreign earnings
• Calculating the U.S. tax cost on dividends of foreign earnings – treatment of excess direct and indirect foreign tax credits
• Determining the U.S. tax consequences of foreign check-the-box elections and merger and acquisition activities
• Interrelationship with the FIN48 rules for recognizing taxes attributable to a contested tax position

12:15 pm LUNCHEON  
 

1:15 pm Structuring Foreign Disregarded or Check-the-Box (CTB) Entities

• Choosing the right vehicle for investing overseas - branch v. corporation v. hybrid entity
• Understanding the CTB rules for foreign entities – planning for S corporations or LLCs
• Reporting transactions involving branches and foreign disregarded entities – computing Sec. 987 gains/losses – new Form 8858
• U.S. tax consequences of dual consolidated losses – new rules for overall U.S. or foreign losses

3:00 pm Refreshments Break 
 

3:15 pm Complying with the IRS Rules for Intercompany Transactions

• Preparing an economical Transfer Pricing Study - avoiding penalties under Sec. 482 – using an APA to provide certainty
• Computing the arm’s-length profit on related party sales – determining the Best Method - impact of the “first sale” rule
• Understanding the new intercompany service regulations - charging for headquarter services and imbedded intangibles
• Migrating intangibles to an offshore licensing vehicle – implementing a qualified cost-sharing arrangement
• Collateral U.S. tax consequences of a Sec. 482 audit adjustment – interrelationship with rules for uncertain tax position (UTP)

5:00 pm Meeting Adjourns for the Day 
 

7:30 am Continental Breakfast
 

8:00 am Corporate International Tax Compliance - 2011

• Obtaining the data from overseas for preparing and filing Form 5471 - key issues in reviewing Form 5471 for foreign affiliates
• Review of key U.S. international reporting forms – Form 926, 1118, TD F 90-22.1 and 8838
• E-filing issues for international operations – new Form 8858 for CTB entities
• Preparation of Form 8886 and Schedule M-3 for reporting significant book-tax differences

9:00 am Taxable Transfers of CFC Stock by U.S. Shareholders

• Computing the U.S. tax on gain from the sale of shares in a foreign corporation under Sec. 1248
• Obtaining foreign tax credit benefits on sales of shares in first and lower tier CFCs - consequences of making a Sec. 338 election
• Comparison of the Sec. 1248 tax consequences of a sale of subsidiaries v. pre-sale repatriation of profits

10:15 am Break for Refreshments

10:30 am Tax-Free International Mergers and Acquisitions under Sec. 367

• Evaluating the use of the new statutory merger or consolidation rules for an acquisition of foreign tangible and intangible assets
• Application of Sec. 367(a) to the incorporation of a new foreign company
• GRA reporting and compliance requirements for international mergers and reorganizations– substitution principles under recent regulations
• Conducting tax due diligence – negotiating tax representations and warranties

12:15 pm Meeting Ends

EDUCATIONAL COURSE CREDIT

Up To 20 CPE Credit hours available

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.

Up to 20 CLE Credit hours available

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 .

Hardship Policy

Bloomberg BNA offers a hardship policy for attorneys earning less than $50,000 per year. If an attorney wishes to take advantage of this option, he or she must contact Bloomberg BNA directly. For attorneys who are unemployed or earning less than $35,000 per year, a full discount off the price of the program will be awarded upon written proof of hardship. Attorneys earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. Any attorney working in the public service sector also qualifies for a special price. If you have further questions regarding the hardship policy or seek additional 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.