Networking Seminars announces its intermediate level international tax course.  This seminar will provide the necessary information on the recent changes to the international tax rules and regulations, as well as, discuss the Obama Administration’s international tax proposals.  It will also cover how to handle an IRS audit.  This is the perfect opportunity to meet our international tax experts and have them explain the recent and proposed regulations that will affect U.S. multinationals.  

There is no advance preparation.  Prerequisite is an introductory course on international tax or its equivalent.  This course is for CPAs, corporate tax & finance professionals including tax directors, senior tax managers, VP Taxes, Controllers, CFOs, tax specialists and tax attorneys and counsel.  This seminar is non-transitional which is appropriate for experienced attorneys.

Earn 15.5 CPE/CLE Credits

DAY ONE: WEDNESDAY, JUNE 16, 2010

8:00 am Registration & Breakfast

8:30 am New Contract Manufacturing Regulations

• Rejection of the ‘Its” Argument
• The New Definition of Manufacturing
• Branch Rule Changes
• Multiple Branch Rules
• Examples

10:30 Refreshment Break

10:45 am The New Service Rules Under Section 482

• General Observations on Headquarter Company Costs
• Specified Covered Services  and the Business Judgment Test
• When a Related Party Must Charge for Services
• The Benefits of Intercompany Service Agreements
• Allocation of Costs From Shared or Centralized Services

12:00 pm Networking Luncheon

1:15 pm International M&A Developments

• Notice 2008-10 and the “Killer B” Regulations
• New Proposed Regulations Under Section 367(a)(5) for Outbound Transfers
• Gain Recognition Trigger Traps and Improper Valuations
• Modification of the Basis Rules for Section 956
• New Section 1248 Regulations
• Proposed Regulations Under Section 336 (e)

2:45 pm Refreshment Break

3:00 pm Treaty Developments/Current International Audit Issues

• New US Model Treaty Changes
• The Changing Definition of a Permanent Establishment
• New US/Canada Protocol
• US/UK Competent Authority Agreement
• Hybrid Instruments
• Cost Sharing

4:30 pm  The Obama International Tax Proposals

• Reform of the Foreign Tax Credit
  • Pooling for the “deemed-paid” credit
  • Preventing the split of foreign income and foreign taxes

• Tax Changes To Transfers Of Intangibles
  • New limits on the transfers of intangibles offshore
  • Current taxation of intangibles offshore

• Deferral of Interest Expense Related to Deferred Income
• Other Proposed Changes
  • Disallowance of excess reinsurance premiums
  • Repeal Of 80/20 rules
  • Modification of dual capacity taxpayer rules

5:30 pm Questions & Answers

5:45 pm Seminar Adjourns for the Day

DAY TWO: THURSDAY, JUNE 17, 2010

8:00 am Continental Breakfast

8:45 am Treaty Developments/Current International Audit Issues

• New US Model Treaty Changes
• The Changing Definition of a Permanent Establishment
• New US/Canada Protocol
• US/UK Competent Authority Agreement
• Hybrid Instruments
• Cost Sharing

9:45 am Refreshment Break

10:00 International Tax Accounting and Transparency

• The Changing Role of Tax Departments
• FAS 109 Liability Method
• Coping With Sarbanes-Oxley and Fin 48
• Transfer Pricing Documentation
• Transparency in the Competent Authority Process
• Foreign Tax Credit Redeterminations

11:30 am Luncheon

12:45 pm Tax Planning For Losses       

• CFC Losses and Deficit Rules
• Worthless Stock Deductions
• Losses On The Disposition Of A CFC
• Foreign Tax Credit Implications And PTI
• OFL, ODL and Other Domestic Loss Rules

2:30 pm Refreshment Break

2:45 pm Tax Controversies 

• Federal and State Tax
• Audit process and Administrative Appeal
• Resolving Disputes
• Understanding of Tax Matters Arising in Controversies
• FIN 48 Analyses

3:45 pm Question & Answers

4:00 pm Seminar Concludes