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. international taxation is a major focus of the Obama Administration and of great concern to U.S. tax practitioners at multinational companies. This seminar will provide the necessary information on the recent changes and proposed legislation.  It will also provide practical advice on how to handle tax controversies and tax planning for losses in this global recession.

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, JULY 21, 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, JULY 22, 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

SEMINAR LOCATION:

HOTEL MONACO
501 Geary Street at Taylor
San Francisco, CA  94102

Reservations 866.622.5284
Hotel 415.292.0100