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Foreign Tax Credits - These course materials will review computing the indirect foreign tax credit, how to recapture foreign source losses and how to apply the indirect credit to controlled foreign corporations. These course materials from November 18, 2009 include: General Overview of Rules Affecting Foreign Tax Credits by David Kim & Melinda Misanko of KPMG; Understanding Basic Foreign Tax Credit Mechanics Under Sections 901, 902, 903 & 960 by Rob Misey of Reinhart Boerner Van Deuren; Understanding the Section 904 Foreign Tax Credit Limitation by Kim Stawski, PricewaterhouseCoopers LLP; Understanding the Look-Through Rules Under Section 904(d) (3) and (4) by Tom Kinzler & Matt Battin of PricewaterhouseCoopers LLP; Foreign Source Losses and Overall Domestic Losses and their Effect on the Foreign Tax Credit Limitation by Ritu Agarwal of Deloitte Tax LLP; Impact of President Obama's Tax Proposal on Foreign Tax Credits by David Kim from KPMG LLP.
Transfer Pricing - Transfer Pricing is the most important international tax issue facing multinationals and will be have added scrutiny by the IRS as they plan to step up their examination of Transfer pricing reports. These course materials from October 27 & 28, 2009 include: Transfer Pricing: State of the “Art” by Steve Wrappe of Ernst & Young LLP; Working With the New Service Regulations by E. Miller Williams of Ernst & Young LLP; Adapting to the New Cost Sharing Regulations by David Bowen of Grant Thronton; Treatment of Intangibles by Sean Foley of KPMG LLP; Transfer Pricing Differences in Other Countries by Paul Mulvihill of Ernst & Young LLP; How to Conduct a Transfer Pricing Study by Rob Misey of Reinhart Boerner Van Deuren; Handling an IRS Transfer Pricing Examination by Rob Miseyof Reinhart Boerner Van Deuren; Advanced Pricing Agreements/Competent Authority by Richard McAlonan from Deloitte Tax LLP; Transfer Pricing Planning by Steve Wrappe from Ernst & Young LLP
Advanced International Tax - These course materials are from our advanced international tax course that cover the most complex international tax issues facing U.S. multinationals. These course materials are dated Tuesday, September 22, 2009 and cover: The Concept of Permanent Establishment Under Tax Treaties by James Riedy, McDermott Will & Emery, Washington, Dc; Transfers of Intangible Assets by Rocco Femia, Miller & Chevalier, Washington, DC; Inbound and Outbound Transactions by John Barrie, Bryan Cave LLP, Washington, DC; Dual Consolidated Losses by Doug Holland, KPMG LLP, Washington, DC; Foreign Exchange by Peter Daub, Baker & McKenzie, Washington DC; Financing Foreign Subsidiaries by Mark Opper, McDermott Will & Emery, Washington, DC
International Tax Update - These course materials will explain the latest developments in international taxation to reduce corporate taxes on foreign earnings for companies with operations abroad. These course materials include the following presentations: Overview to Recent Changes & President Obama's International Tax Proposals by Rick Giolitti, Partner, PricewaterhouseCoopers LLP; New Contract Manufacturing Regulations by Jeff Levenstam & Elizabeth Wutzke, of Ernst & Young LLP; Recent Changes to the Foreign Tax Credit by Mike Harper, Director, PricewaterhouseCoopers LLP; International M&A Developments by Steven H. Mundschau, Director, Ernst & Young LLP; Treaty Developments/Current International Audit Issues by John Ryan, Partner, McDermott Will & Emery; The New Service Rules Under Section 482 by Rocco Femia, Member, Miller & Chevalier, Washington DC
Introduction to International Tax - These materials give an overview of these various international tax isseus: The Source of Income by Greg Bryant from PricewaterhouseCoopers LLP; Expense Apportionment by David Reid from PricewaterhouseCoopers LLP; Earnings and Profits by Greg Bryant from PricewaterhouseCoopers LLP; The Foreign Tax Credit by Rodney Lawrence from KPMG LLP; Subpart F Income by Margaret A.R. Shulman of Ernst & Young LLP & Robert Misey from Reinhart Boerner Van Deuren; Transfer Pricing by Robert Misey from Reinhart Boerner Van Deuren
U.S.-Latin America Investment &Tax Forum including the Caribbean - Topics covered include: Current Tax Developments and Hot Issues; Analysis of the Tax Systems, Country Deductions, Exemptions and Incentives; Transfer Pricing Update; Mergers & Acquisitions and Joint Ventures; Tax Treaty Benefits and Local Holding Company; Permanent Establishments and OECD Trends; Tax Compliance including Litigation, Audits, Controversies; Dealing with Tax Losses and Bad Debts and Forced Dispositions; Tax Planning Alternatives and Future Concerns in the Regions. Country/Speaker: Argentina, Cristian Rosso Alba, Rosso Alba, Francia & Ruiz; Brazil, Miguel A. Valdés, Machado Associados Advogados e Consultores; Chile – Jorge Espinosa, Lataxnet Chile Abogados & Consultores; Colombia - Alfredo Lewin, Lewin & Wills Abogados; México, Ignacio Sosa López, Ortiz, Sosa, Ysusi y Cía., Costa Rica - Adrian Torrealba, Facio & Cañas; Venezuela - Juan Carlos Garantón, Torres, Plaz & Araujo ; Puerto Rico - Fernando Goyco, Adsuar Muniz Goyco Seda & Perez-Ochoa P.S.A.; Caribbean - Paul Tadros, DSN Consultants Inc.
Wine Law in America includes the presentations from the seminar on the topics such as: Selling Wine in America in the 21st Century by Richard Mendelson, Partner, Dickenson Peatman & Fogarty, Napa; Intellectual Property in the Wine Industry by Scott Gerien, Partner, Dickenson Peatman & Fogarty, Napa; Conflicts between Brands and Appellations: The Case of Calistoga by Richard Mendelson & Scott Gerien of Dickenson Peatman & Fogarty; How to Get into the Wine Business by Jim Terry, Tom Carey, Mike Mann of Dickenson Peatman & Fogarty; Planting a Vineyard or Constructing a Winery: Understanding Entitlements and Regulatory Costs and Timelines by Rob Anglin & Cathy Roche from Dickenson Peatman & Fogarty, James Bushey from PPI Engineering and Richard Nichols of LSA Associates, Inc.; Counterfeit Wines by William Casey & Andrew Wanger, Partner, Clyde & Co., San Francisco
MUSIC IN FILMS by David Steinberg, Partner, Heenan Blaikie includes the following materials on Master Recordings and Publishing; An Explanation of Music Rights. Samples of Synch License Agreement; Composer Agreement and Master Use Agreement.
Film/TV Production & Finance Summit Workshop materials are approximately 60 pages and include: Opening Steps Memo; "Are We Closed Yet?" – some production financing tips; Sample Distribution Agreement; Sample Assignment and Direction; Sample Interparty Agreement; Sample Completion Agreement; Sample Completion Guarantee - by David Steinberg of Heenan Blaikie in Toronto.
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