Subpart F Rules on Taxation of Controlled Foreign Corporations
Navigating the Complexities in Tax Planning for Multinational Companies
Recording of a 90-minute CLE webinar/teleconference with Q&A
Conducted on Tuesday, March 9, 2010
Recorded event now available
This CLE webinar will prepare counsel and advisors to multi-national companies to meet the requirements of the current Subpart F rules governing the taxation of controlled foreign corporations. The panel will review recent enforcement developments and discuss key tax planning strategies.
Description
Subpart F governs the taxation of income generated by controlled foreign corporations (CFCs). Certain non-U.S. earnings are deemed distributed under the complex Subpart F rules such as passive income and income from certain sales of goods or services.
Several new developments in the Subpart F rules warrant attention of tax counsel and advisors, including guidance allowing CFCs to improve liquidity without increasing the amount of "U.S. property."
The Obama administration has made international tax reform a critical element of proposed tax reform initiatives as the government seeks to close perceived tax loopholes in an effort to raise much-needed revenue. As a result, multinational companies can expect to see more rigorous IRS enforcement.
Listen as our authoritative panel of tax attorneys discusses Subpart F rules for multinational companies, recent legal and enforcement developments, and tax planning strategies.
Outline
- Determination of a controlled foreign corporation (CFC)
- What is a CFC?
- Control tests
- Attribution rules
- Tax treatment of CFC income
- In general
- Subpart F income
- Exceptions and limitations
- Special issues and legal developments
- Investments in U.S. property
- Treatment of previously taxed income
- Subpart F Income partnership blocker transactions
- Legislative reform
Benefits
The panel will review these and other key questions:
- What is the effect of voting agreements on CFC determination?
- How can CFCs take advantage of recent guidelines allowing CFCs to improve liquidity without increasing the amount of U.S. property under section 956?
- What tax reform initiatives and enforcement trends can multinational companies expect to see in the near future?
Upon completing this seminar, the attendee will learn about new developments affecting the application of SubPart F rules of the IRS Code on the taxability of income generated by controlled foreign corporations. The attendee will learn the impact of voting agreements on CFC determinations and the potential advantages for CFCs under Section 956 guidelines.
Faculty
Daniel L. Gottfried,
Partner
Rogin Nassau, Hartford, Conn.
His practice encompasses domestic and international business transactions, as well as federal, state, and international tax planning, including corporate mergers, acquisitions and dispositions, joint ventures, partnerships and S corporations. He is regularly called on to assist business clients with cross-border expansion, including expansion into the U.S. and abroad.
Jeff Rubinger,
Partner
Holland & Knight, Fort Lauderdale, Fla.
He practices focuses on domestic and international taxation. He has experience in a broad range of transactions involving U.S. taxpayers doing business overseas, foreign taxpayers doing business in the U.S., tax planning for mergers and acquisitions, restructurings and joint ventures, and federal, state and local tax issues with corporate reorganizations, partnerships, and S corporations.
Michael J. Miller,
Partner
Roberts & Holland, New York
He has provided U.S. tax advice to domestic and international clients for more than 15 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid creation of U.S. permanent establishment and developed structures to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other rules for minimizing U.S. tax.
Ordering
Online CLE - Audio Recording
Includes audio streaming of full program plus handouts (available 24 hours after live seminar).
CPE: Self-study CPE is not offered on online webinars.
CLE:
Pre-approved for participatory or non-traditional/alternate format credit in: CA, HI*, NY*, WV*.
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Upon request, also available in: CO, CT*, GA, ID, KY, LA*, ME, NC, ND, NE, NH, NM, NV, OR*, SC, TN, UT, WI*, WY. If you are applying for credit in one of these states, make sure to select those states when placing your order.
(*Indicates that Strafford must report attendance.)
Online CLE Audio $297.00
Available 24 hours after the live event
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Includes full event recording plus handouts (available after live seminar).
CPE: Self-study CPE is not offered on recorded events.
CLE: Pre-approved for self-study credit in: AK, AZ, CA, CT, FL, HI, MO, MT, NY, TX, VT, WA, WV. Upon request, self-study credit is also available in: CO, GA, ID, KY, ME, ND, NE, NH, NM, NV, OR, UT, WI, WY. If you are applying for self-study credit in one of these states, contact Strafford CLE at 1-800-926-7926 ext. 35 or CLE@straffordpub.com.
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Available three business days after the live event
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plus $9.45 S&H
Available ten business days after the live event
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Available 24 hours after the live event
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plus $9.45 S&H
Available ten business days after the live event
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Customer Reviews
Concise and accurate presentation. Handouts very informative.
William Moran
Shire Canada
This was an excellent teleconference; one of the best I have listened to. The speakers were all very knowledgeable on the subject, but importantly, they were able to present in a very direct, easy to listen to and understand style.
Jose E Guzman, Jr.
Nossaman
Very concise - provided what was needed, yet also included many examples, thoughts and ideas.
Ron Keith
Skilled Care
Excellent topics, discussed very well.
McClure King
Dearborn National
The speaker's practical discussions were particularly helpful.
Kenneth J. Clarkson
Sullivan, Ward, Asher & Patton
Tax Law Advisory Board
Tax Partner
Steptoe & Johnson
Of Counsel
Morrison & Foerster
Partner, Federal, State and International Tax Planning
Rogin Nassau
International Tax and Tax Controversies Partner
DLA Piper
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Transactional Tax Partner
McKenna Long & Aldridge
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Nixon Peabody
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Pepper Hamilton
Tax Controversy Partner
Crowell & Moring
Of Counsel
Skadden Arps
Peter Stathopoulos
Managing Director, State and Local Tax Practice
Bennett Thrasher
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
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