Networking seminars is pleased to announce our introductory seminar on international taxation offered in various cities across the United States.  The goal as an international tax practitioner is to reduce corporate taxes on foreign earnings for companies with operations abroad.  At this basic level course with group live instruction you will learn the basic principles of international taxation, while also providing you the opportunity to meet with and learn from our experienced faculty, as they provide you with a comprehensive overview of how to reduce U.S. taxes on foreign income for U.S. multinational.

There is no advance preparation for this basic level course on taxes.  This course is designed for those new to international taxation or those looking to refresh their jobs skills in corporate taxation.  This course is for CPAs, corporate tax & finance professionals, tax specialists, tax attorneys and counsel and those with an interest on how to reduce U.S. taxes on foreign income.  This seminar is transitional and non-transitional which is appropriate for both newly admitted attorneys and experienced attorneys.

There are up to 15 CPE Credits Available.

DAY ONE: MONDAY, JUNE 14, 2010

8:00 am Registration and Continental Breakfast 

8:30 am Overview of U.S. International Taxation

8:45 am The Source of Income

• Residence For Taxation
• Income From a Single Source
• Income From Mixed Sources
• Establishing Foreign Title Passage-The Use of Incoterms
• Tax Planning to Create or Increase Foreign Source Income

9:45 am Expense Apportionment

• The Basic Rules of Allocation and Apportionment
• The Apportionment of R&E Expenses
• Asset Apportionment of Interest Expense
• The Apportionment of SG&A Expenses
• Apportionment of Other Expenses
• Tax Planning in Expense Apportionment

11:00 am Refreshment BreaK 

11:15 am Earnings and Profits

• The Importance of Earnings and Profits in International Tax
• The Steps in Preparing an Earnings & Profits Study
• Preparing a Computation of Earnings & Profits-Pre-1987
• Preparing a Computation of Earnings & Profits-Post-1986
• Common Earnings and  Profits Adjustments
• Practical Issues Involved in Calculating Earnings and Profits 

12:30 pm Luncheon

1:30 pm The Foreign Tax Credit

• Determining A Creditable Tax
• The Foreign Tax Credit Limitation Formula
• The Direct Credit
• The Deemed Paid Credit
• Foreign Tax Credit Baskets

3:00 pm Refreshment Break 

4:00 pm Subpart F Income

• The Determination of a Controlled Foreign Corporation
• Understanding Foreign Base Company Income
• Exceptions and Limitations to Subpart F
• Section 956 Investments in US Property
• Treatment of Previously Taxed Income

5:00 pm Seminar adjourns for the day

DAY TWO: TUESDAY, JUNE 15, 2010

8:00 am Continental Breakfast 

8:45 am Recap and Overview

9:00 am Passive Foreign Investment Companies

• Classification-The Income Test And The Asset Test
• Exceptions To PFIC Status
• Consequences Of PFIC Status
• Tax Planning For PFICs

10:00 am Refreshment Break 

10:15 am Transfer Pricing

• Overview of Section 482-The Arm’s Length Standard
• Determining The Best Method for Sales Of Products
• What Companies Must Utilize CUP, Resale Price, or Cost Plus
• When CPM Applies-Factors Determining Comparability
• Preparing/Reviewing A Transfer Pricing Study
• Multi-Jurisdictional Use of a Transfer Pricing Study

12:00 pm Luncheon

1:00 pm Income Tax Treaties

• The Essential Elements of Income Tax Treaties
• Business Profits and Permanent Establishments
• Qualifying For Treaty Benefits-Dealing With The Limitation On Benefits Provision 

2:45 pm Refreshment Break

3:00 pm Inbound Tax Planning

• Taxation of Trade or Business Income
• Taxations of Fixed Determinable Annual or Periodic Income

4:00 pm Questions & Answers

4:15 pm Seminar Concludes