San Francisco, CA
December 12 - 13, 2016
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.
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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!
WHY YOU SHOULD ATTEND
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.
WHO SHOULD ATTEND
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 a.m. Registration and Continental Breakfast
9:00 a.m. Introduction and Overview
9:15 a.m. Section 199
• Review of IRS Guidelines
• Practical Considerations Associated with Implementation
• Current trends and risks
10:15 a.m. Subpart F Planning
• Repatriating low tax earnings from a CFC
• CFC Investments in US property
• Section 1248 consequences of disposition of CFC Stock
• Foreign Tax Credit considerations for Subpart F income
11:15 a.m. Coffee Break
11:30 a.m. FATCA
• On board in plain English
• Compliance sanity check
• What your foreign affiliates need to do to avoid 30% withholding and how to help them
12:30 p.m. Luncheon
1:30 p.m. Transfer Pricing Update
• IRS Roadmap – Audit Trends
• Current Proposals and Impact on BEPS
• Reorganization of LB&I
• Impact of Key Cases Litigated in 2016
3:00 p.m. Coffee Break
3:15 p.m. Final and Temporary Regulations under Section 385
• Changes from the Proposed Regulations
• Documentation requirements
• “Per se” stock rules
• Prospects for judicial challenge
4:45 p.m. Q & A
5:00 p.m. Seminar Adjourns for the Day
8:30 a.m. Continental Breakfast
9:00 a.m. Preserving Privilege and Work Product
• Update and current trends in maintaining privilege and work product
• Best practices for protecting documents
• Federal Actions Influencing States’ Transfer Pricing Activities
10:15 a.m. International Tax Aspects of Currency Transactions
• Section 986 - Transactions Issues including Elections
• Section 987 - Explanation of new proposed Section 987 regulations
• Subpart F impacts of foreign currency gains and losses
11:15 a.m. Coffee Break
11:30 a.m. 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
12:30 p.m. Luncheon
1:30 p.m. 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
• Code and Treaty Developments
2:45 p.m. 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
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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 firstname.lastname@example.org.
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.
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