Networking seminars is pleased to announce our introductory seminar on international tax.  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.

There is no advance preparation for this basic level course on taxes.  This course is for corporatie tax, finance and accounting executives, tax attorneys and counsel and CPAs.  This seminar is transitional and non-transitional which is appropriate for both newly admitted attorneys and experienced attorneys.

EARN 8 CPE/CLE Credits

Registration Information

Chairperson:

Jeff Levenstam, Partner, Ernst & Young LLP, San Francisco

MONDAY, AUGUST 2, 2010

8:30 am - Registration and Continental Breakfast

8:45 am - Introduction & Overview

9:00 am - Source of Income and Expense Apportionment

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

Brian Joyce, Partner, Ernst & Young LLP, San Jose, CA

10:30 am - Break

10:45 am - 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

Gordon Beckstead, Partner, International Tax, Deloitte Tax LLP, San Jose, CA

12:00 pm - Luncheon

1:00 pm - CFCs, PFICs, and Subpart F Income

• The Determination of a Controlled Foreign Corporation (“CFC”)
• Classification-The Income Test And The Asset Test
• Exceptions To PFIC Status
• Consequences Of PFIC Status
• Tax Planning For PFICs
• Understanding Foreign Base Company Income
• Exceptions and Limitations to Subpart F
• Section 956 Investments in US Property
• Treatment of Previously Taxed Income

Beth Wutzke, Senior Manager, Ernst & Young LLP, San Francisco, CA

2:30 pm - Break

2:45 pm - 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

Matt Jennings, Manager, Transfer Pricing, Ernst & Young LLP, San Francisco, CA

4:00 pm - 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 

Shannon M. McCormick, Manager, International Tax Services/Financial Services Industry, Ernst & Young LLP, San Francisco, CA

5:00 pm - Seminar Concludes

VIEW THE INTERNATIONAL TAX UPDATE ON AUGUST 3, 2010 IN SAN FRANCISCO

Seminar Location: 

Regus Bay Bridge Conference Room
One Market Street
Spear Tower, 35th Floor
San Francisco, CA  94105

Recommended Hotels:

Hyatt Regency San Francisco
5 Embarcadero Center, San Francisco, California 94111
Tel: +1 415 788 1234
Ernst & Young Discounted Corporate Rate is $189 per night
http://www.hyatt.com

The Palace Hotel
2 New Montgomery Street, San Francisco, California 94105
Tel: +1 415 512 1111
Ernst & Young Discounted Corporate Rate is $208 per night
www.sfpalace.com