eLearning

Year-End Tax Planning for U.S. Multinational Corporations

Price: $224 eLearning

FULFILL ALL YOUR CONTINUING EDUCATION CREDITS FOR $399

Sign up today for an entire year of unlimited access to relevant, timely professional learning courses, including webinars, eLearning courses and OnDemand offerings, and keep your professional credits up to date. All for just $399.

Learn more about the subscription!

SUBSCRIBE NOW

DESCRIPTION

During the year, U.S. multinationals engage in numerous cross-border transactions or operations that can have implications on their U.S. federal tax return.  Those transactions may include distributions from foreign subsidiaries as well as transactions that result in deemed income inclusions as a result of the application of certain anti-deferral rules of the Code, such as the Subpart F rules.  Additionally, certain filings may be required with their U.S. federal tax return in order to avoid having to recognize gain on a cross-border restructuring transaction or to enable the utilization of a loss.     

This practical program from Bloomberg BNA, Year-End Tax Planning for U.S. Multinational Corporations, presented by Joseph Calianno and Jeffrey S. Korenblatt, provides advisors and taxpayers with important information in identifying selected transactions, events and filings that can have significant U.S. federal income tax implications. 

During this program, Calianno and Korenblatt will discuss certain rules that can impact a U.S. multinational’s return relating to:
• Distributions from foreign subsidiaries, including the implication of such distributions under the foreign tax credit
• Subpart F inclusions and investments in U.S. property that may require a U.S. taxpayer to recognize income 
• Coordination between actual distributions and deemed distributions
• Gain recognition agreements and dual consolidated losses and certain required U.S. federal tax return filings
• Certain cross-border filings that may be required with the U.S. multinational’s U.S. federal tax return, including Forms 926, 5471, 8865, 8858 and others and the implications of failing to file

Educational Objectives
• Review important international tax rules and the impact of such rules on a U.S. multinational’s U.S. federal tax return
• Identify when a U.S. multinational may be required to file certain forms relating to cross-border transactions with its U.S. federal tax return and the potential implications of a failure to file the requisite forms

This is a recorded webinar that originally ran live on October 23, 2013. As an eLearning course, you must pass the final exam of this course to receive CPE credit.

SPEAKERS

JOSEPH CALIANNO, CPA, MBA, JD, LLM, PARTNER AND INTERNATIONAL TECHNICAL TAX PRACTICE LEADER, WASHINGTON NATIONAL TAX OFFICE OF GRANT THORNTON LLP

Joseph Calianno, CPA, MBA, JD, LLM Tax, is a Partner and International Technical Tax Practice Leader in the Washington National Tax Office of Grant Thornton LLP.  He practices in all areas of International Tax, with an emphasis on cross-border transactions.  He currently is the Chair of the American Bar Association’s Foreign Activities of U.S. Taxpayers Committee and previously was the Chair of the American Institute of Certified Public Accountant’s International Tax Technical Resource Panel.   Mr. Calianno previously served as a Special Counsel to the Deputy Associate Chief Counsel (International) in the Office of Chief Counsel at the Internal Revenue Service.


JEFFREY S. KORENBLATT, JD, INTERNATIONAL TAX PARTNER, REED SMITH LLP

Jeffrey S. Korenblatt, JD, is an International Tax Partner at Reed Smith LLP.  A prolific writer and speaker in the international tax practitioner community, he advises taxpayers on the tax-efficient structuring of domestic and cross-border mergers, acquisitions, reorganizations, spin-offs, redemptions and liquidations, as well as on complex cross-border business structuring and supply chain management.