A two-day introduction and update session with live group instruction on the practical U.S. tax issues in documenting and reporting the tax and accounting results of foreign entities and operations.

Course Level: basic to intermediate; Delivery Method: live group

Learning Objectives

• Find out how companies obtain foreign tax data from affiliates overseas for preparing Forms 5471
• Discover how to report the results of check-the-box and other foreign disregarded entities on new Form 8858
• Ascertain how to satisfy the tax reporting requirements under Secs. 367 and 1248 for foreign mergers and reorganizations
• Learn how to compute the amount of tainted Subpart F earnings and file an election to exclude Subpart F amounts
• Review the preparation of Form 1118 and how to prepare worksheets for computing earnings and profits (E&P) and the amount of indirect credit (Sec. 78) gross-up
• Understand how the expense apportionment rules under Reg. Sec. 1.861-8 affect foreign tax credit benefits
• Find out recent trends in transfer pricing planning and managing cross-border audits in multiple tax jurisdictions

All paid attendees will receive the Bloomberg BNA Portfolio:(#947) - Reporting Requirements under the Code for International Transactions

*One Portfolio per paid attendee. Quantities are limited.

Prerequisites

There are no prerequisites for attending this program.

SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS

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.

New York - Bloomberg LP

731 Lexington Ave

New York, NY 10022

Tel: 212.318.2000

Day One

8:00 am Registration and Continental Breakfast

8:30 am CITE Welcome and Introduction

8:45 am Reporting the Results of Foreign Corporations  

• When is a foreign corporation required to file a return with the IRS? - Form 5471
  
  
• Preparation of U.S. GAAP financial statements - foreign bank account reporting - Form TDF 90-22.1, Form 5471
  
  
• Computing earnings and profits for CFCs and 10/50 companies - Schs. C, H and J, Form 5471
  
  
• Preparation of Schedule M, Form 5471 - reporting intercompany transactions

10:30 am Refreshment Break  

10:45 am U.S. Tax Issues in Structuring Foreign Operations  

• Selecting a foreign corporate or pass-through entity - when a foreign entity can elect to be taxed as a conduit - per se corporations
  
  
• Understanding the U.S. tax consequences of making a check-the-box (CTB) election on Form 8832 - Dover and Guardian Industries cases
  
  
• Interrelationship with foreign tax credit and Subpart F provisions
  
  
• Recapture of overall foreign losses and dual consolidated loss issues

12:15 pm LUNCHEON

1:30 pm Maximizing Foreign Tax Credit Benefits  

• Claiming direct foreign tax credit benefits - maintaining pools of foreign taxes available for credit
   


• Applying the foreign tax credit limitation formula for passive or general basket income and taxes



• Computation of the Sec. 78 gross-up for deemed paid taxes - interrelationship with the subpart F FPHCI rules



• FTC recharacterization and resourcing rules - treatment of overall foreign and domestic losses and separate basket limitation recapture
   

3:00 pm Refreshment Break  

3:15pm Understanding the Subpart F Provisions  

• How Subpart F accelerates the U.S. tax on earnings of CFCs - recent Jobs Act changes involving Subpart F and foreign PHCs
  
  
• Affirmative use of Subpart F income and investments in U.S. property - Jobs Act changes to Sec. 956 inclusions
  
  
• Application of the look-through rules and interrelationship with the foreign tax credit rules
  
  
• Planning for distributions of previously-taxed income (PTI) and other CFC earnings

4:45 pm Meeting Adjourns for the Day  

Day Two

7:30 am Continental Breakfast  

8:00 am Corporate International Tax Compliance  

• 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 8621
   
• Maintaining worksheets for new Form 8858 for CTB entities
   
• Preparation of Form 8886 and Schedule M-3 for reporting significant book-tax differences

9:15 am Expense Apportionment  

• How expense apportionment affects foreign tax credit and export tax benefits
  
  
• Understanding key definitions for class of income, statutory and residual groupings and gross income apportionment
  
  
• Application of expense apportionment to interest and research expense - treatment of stewardship, state tax and charitable deductions
  
  
• Adopting a plan of apportionment for sales, general and administrative expense

10:30 am Refreshment Break  

10:45 am Documenting Related Party Transactions

• Effectively conducting a Transfer Pricing Study to mitigate adjustments in today's economic environment
   
• Proper use of economists in the preparation of a study
   
• Satisfying the year-end Sec. 6038A documentation rules for foreign-controlled U.S. companies – preparing Form 5472
   
• Avoiding IRS penalty assessments under Sec. 6662(e)
   
• Role of documentation in the audit process and FIN 48 implications

12:15 pm LUNCHEON  

1:30 pm Computing the Gain from the Sale of CFC Shares under Sec. 1248  

• How the U.S. taxes gain from the sale of shares in a CFC - interrelationship with the reorganization rules under Sec. 367(b)
  
  
• Determining gain (loss) on the liquidation of a CFC under Secs. 331 and 332
  
  
• U.S. tax consequences of making a Sec. 338 election on the sale of a CFC
  
  
• Comparison of the Sec. 1248 tax consequences of a sale of subsidiaries v. pre-sale repatriation of profits

2:30 pm Refreshment Break  

2:45 pm Transfers of Stock and Assets to a Foreign Corporation  

• How to qualify an outbound transfer of assets to a foreign subsidiary or joint venture as tax-free under Sec. 367(a) - reporting the transfer on Form 926
  
  
• Special rules for transfers of intangibles under Sec. 367(d)
  
  
• Organizing a foreign corporation or holding company - completing a Gain Recognition Agreement (Form 8838)
  
  
• Special issues involving non-taxable mergers and reorganizations under Sec. 367(b)

4:30 pm Meeting Ends

EDUCATIONAL COURSE CREDIT

Up To 16 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 16 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 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.