2016 Corporate Tax Developments: The Year in Review - San Francisco

San Francisco, CA

Register Early and Save!

Year-End Tax Pass


Fulfill all of your remaining CPE/CLE credits with entry to an unlimited number of upcoming Bloomberg BNA tax seminars and webinars in 2016 for less than the price of two seminars.

Click here to learn more and purchase your pass!


This two-day technical session will focus on tax planning strategies to be used to reduce your company’s worldwide tax rate. This advanced level seminar will also examine the most up-to-date corporate tax developments that will affect your company’s bottom line.

Course Level: Technical Update Delivery Method: Live Group

By attending this event, attendees will be able to:
• Discuss CFC investments in U.S. property
• Learn key year-end tax, securities and exchange control filing/reporting and requirements outside the U.S.
• Review current trends in corporate inversions
• Understand Subpart F impacts of foreign currency gains and losses
• List arbitration and competent authority developments
• And more!

Changes in U.S. and foreign laws, recent court decisions, and tax rulings can have a major impact on the tax cost of doing business abroad. Highlights will include recent foreign tax credit and transfer pricing regulations, strategies for repatriating foreign earnings, Subpart F, and earnings and profits issues. Also being covered is FATCA, Sec. 199, currency transactions, tax treaties, and mergers and acquisitions issues including reorganizations.

This program is designed for VP taxes, corporate tax directors, attorneys, tax managers, accountants, corporate controllers, treasurers and CFO, lawyers and tax council. This program with live group instruction is transitional which is appropriate for newly admitted attorneys. There are no prerequisites for attending this program.



8:30 AM Registration & Continental Breakfast

9:00 AM Welcome and Overview

9:15 AM Section 199
• Review of IRS guidelines
• Practical considerations associated with implementation
• Current trends and risks

10:15 AM Subpart F Planning
• Repatriating low tax earnings from a CFC
• CFC investments in U.S. property
• Section 1248 consequences of disposition of CFC stock
• Foreign tax credit considerations for Subpart F income

11:15 AM Break for Refreshments

11:30 AM FATCA
• On board in plain english
• Compliance sanity check
• What your foreign affiliates need to to do to avoid 30% withholding and how to help them

12:30 PM Luncheon

1:30 PM Transfer Pricing Update
• IRS roadmap – audit trends
• Marketing intangibles
• Current proposals and impact on BEPS
• Transfer pricing documentation

2:30 PM Inversions, Repatriations and Other Advanced Cross Border M&A Transactions
• Current trends in corporate inversions
• Intragroup repatriation transactions
• Final regulations on outbound cross-border asset reorganizations
• Notice 2012-39 and its progeny

3:30 PM Break for Refreshments

3:45 PM Merger and Acquisitions Issues Including Reorganizations
• Tax free organizations under Sections 368, 355 and 332
• Taxable transactions under Section 367
• Due diligence considerations in cross border transactions
• Strategic planning opportunities

4:55 PM Question & Answer Session

5:15 PM Seminar Adjourns for the Day


8:30 AM Continental Breakfast

9:00 AM End of the Year Wrap Up by Baker & McKenzie’s Foreign Legal Team
• Panel discussion

10:15 AM International Tax Aspects of Currency Transactions
• Sec. 986 – transactions issues including elections
• Sec. 987 – explanation of new proposed Sec. 987 regulations
• Subpart F impacts of foreign currency gains and losses

11:15 AM Break for Refreshments

11:30 AM Stock Option, Planning and Considerations
• Key year-end tax, securities and exchange control filing/reporting and requirements outside the U.S.
• Planning for 2017 annual grants – key regulatory changes
• Action items for complying with IRC Sec. 409A, e.g., timing of deferral elections
• IRC Sec. 162(m) planning issues

12:30 PM Luncheon

1:30 PM Earnings and Profits Documentation Planning
• Impact of accounting methods in E&P
• Timing of recognition of income and expense deferred options
• Adopting and changing methods

2:30 PM Tax Treaties – Current Thoughts and Considerations
• Partnerships and hybrid entities – entitlement to treaty benefits
• Treaty eligibility benefits for items of income rather than person
• Arbitration and competent authority developments
• U.S. taxation of foreign corporations’ business profits: and other code and treaty developments

3:30 PM Seminar Concludes



December 12 & 13, 2016

Morgan Lewis Conference Center 
1 Market Street, Spear St Tower
San Francisco, CA 94111    

Hotel accommodations are at your own discretion. We suggest the following:

Hyatt Regency – Tel: 415.788.1234
5 Embarcadero Center, San Francisco, CA

Westin San Francisco – Tel: 415.974.6400
50 Third Street, San Francisco, CA

Harbor Court Hotel – Tel:866.792.6283
165 Steuart Street, San Francisco, CA



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 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 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, complaints and cancellations, please contact us at 800.372.1033, or e-mail


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

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.


Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.