International Tax Update San Francisco

Networking Seminars is please to announce its intermediate level international tax course for those looking to update their knowledge and learn about the latest changes concerning international tax policies.  U.S. corporate earnings of income overseas has been a major focus for the Obama Administration and hence become a great concern to corporate tax professionals.  This seminar will provide an update on these proposals as well as other prominent changes.

There is no advance preparation.  Prerequisite is an introductory course on international tax or its equivalent.   This course is for corporate tax, finance and accounting executives, tax consultants, CPAs, tax attorneys and counsel.  This seminar is transitional and non-transitional which is appropriate for both new and experienced attorneys.

Earn 8 CPE/CLE Credits

Registration Information

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

TUESDAY, AUGUST 3, 2010

8:30 am - Registration & Breakfast

8:45 am - Introduction & Overview

9:00 am - Key Issues In Contract Manufacturing 

  • Recent Developments in Contract Manufacturing
  • Current “Best Practices” Structures
  • Service Principals Reform Planning and New Trends
  • Planning for Reform
  • New Trends

Jeff Levenstam, Partner, International Tax Services, Ernst & Young LLP, San Francisco, CA 

10:15 am - Refreshment Break

10:30 am - Services Regulations – Reg. Section 1.482-9

  • 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 

Kalika Khanna, Senior Manager, Transfer Pricing, Ernst & Young LLP, San Francisco, CA 

11:30 am - International Tax Legislative Proposals and Outlook

  • 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

Rick J. Giolitti, Partner, PricewaterhouseCoopers, San Francisco, CA

12:30 pm - Luncheon

1:30 pm - Tax Controversies

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

Alan Summers, Senior Manager, Tax Controversies, Ernst & Young LLP, Portland, OR
Margaret Fung, Executive Director, Ernst & Young LLP, San Jose, CA

2:30 pm International M&A Developments

  • All Cash D Reform
  • Covered Asset Acquisitions - Section 338(g) Developments
  • Section 956 recent developments
  • Section 304 Transactions - Anti-Abuse Rule and Legislation
  • Revised Check-the-Box Election Relief
  • Proposed Regulations Under Section 367(a)(5) for Outbound Transfers

Rich Morris, Senior Manager, International Tax Transactions Group, Ernst & Young LLP, San Francisco

3:30 pm Break

3:45 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

Su Kao-Merck, Senior Manager, International Tax Services, Ernst & Young LLP, San Francisco

4:45 pm Question & Answers

5:00 pm Seminar Concludes

VIEW OUR INTRODUCTION TO INTERNATIONAL TAX AGENDA ON AUGUST 2, 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

 

 

Margaret A. Fung is an Executive Director with the International Tax Services Group of Ernst & Young LLP, and advises multinational corporations on transactional planning and implementation of global tax structures in Europe and Asia.  Ms. Fung has broad experience in serving clients in the semiconductor, e-commerce, telecommunications, software, consumer electronics, retail apparel and consulting services industries.  Her areas of international tax practice include subpart F, contract manufacturing, passive foreign investment company, foreign tax credit, foreign currency transactions, dual consolidated loss, cross-border acquisitions and reorganizations, and tax treaty matters.  Ms. Fung also represents multinational corporations on international tax controversy matters before the IRS.

Rick Giolitti is a Partner in PricewaterhouseCoopers International Tax Services group in San Francisco.  Rick has over ten years experience in PwC’s international tax practice consulting clients on U.S. and foreign tax planning for international operations and foreign clients on U.S. and foreign tax planning with respect to investing and conducting operations in the U.S.  Rick has significant experience working with U.S. clients in connection with outbound investing throughout Europe, Asia and the Americas, including acquisition diligence and integration, structuring foreign operations, foreign tax credit planning and planning to manage subpart F   Rick also consults with U.S. and foreign clients with respect to inbound investing, including planning for effectively connected income, withholding, and related compliance.  Rick also has significant FAS 109 experience with respect to cross boarder operations.

Jeffrey A. Levenstam is an international tax services partner at Ernst & Young LLP based in San Francisco.  He joined the Ernst & Young’s International Tax Services Group in 2005. Jeff has practiced international tax for over 33 years as a tax professional and corporate tax executive. Before joining EY, Jeff served as the Senior Director of International Tax, M&A and Customs at Cisco Systems, Inc. from 2000 to 2005.  Prior to that, Jeff was a partner at another Big Four Firm.  Jeff has extensive experience advising U.S. and foreign based multinational businesses in all aspects of international taxation, including transfer pricing, subpart F and dividend planning, capital structuring and foreign operational issues.  Jeff also has extensive experience in structuring and operating IP ownership and tax efficient supply chain structures. 

Continuing Professional Education Credit

Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. Website: www.nasba.org

For more information regarding our administrative policies such as recomplaint resolution, please contact our office at 914-874-5395 or email info@networkingseminars.net

Continuing Legal Education Credit

Networking Seminars offers Continuing Legal Education (CLE) Credits for our seminars. Continuing Legal Accreditation will be sought by those who request it at the seminar.  To receive credits attendees are required to sign-in and sign-out on our record of attendance sheet each day of the conference.  Each state will have final approval on the exact number of credits granted.  For questions regarding CLE and for pre-filing for CLE for a seminar please contact us at 914-874-5395.  We offer tuition assistance for those who are currently unemployed or in need of financial aid.