International Business: Federal Tax Planning Update
Alternative Approaches for the Latest Forms and Reports, Audit Practices and Rulings
Recording of a 125-minute CPE/CLE webinar with Q&A
This teleconference will prepare tax professionals to refine planning techniques and structures based on 2010 U.S. tax developments that affect international business structures used by both corporations and smaller entities.
Outline
- Relevant U.S. legislative changes
- Education Jobs and Medicaid Assistance Act of 2010, H.R. 1586
- International tax extenders shifted from separate tax extender bill onto this legislation
- Prohibition against foreign tax credit-splitting
- Denial of foreign tax credits for disqualified portion of foreign tax paid on covered asset acquisition
- Repeal of 80/20 rules for interest paid and U.S. withholding
- Other aspects
- HIRE Act, H.R. 2847
- New international tax reporting requirements
- Withholding on income from U.S. financial assets held by foreign financial institutions
- Possible upcoming legislation
- After recess, Congress was to consider look-through treatment of payments between related CFCs
- Education Jobs and Medicaid Assistance Act of 2010, H.R. 1586
- Ongoing compliance challenges
- FBAR issues and new FATCA 6038D form
- Other new federal forms
- Estate and gift tax issues
- Estate tax suspended in 2010, scheduled to return in 2011 with lower exemption
- Effects on international structures
- IRS audit treatment of international structures
- Adding many more examiners
- Adjustments to international tax planning to consider, in light of these and other developments
Benefits
The panel will analyze these and other important developments:
- New federal laws: International tax implications of the Education Jobs and Medicaid Assistance Act and Restore Employment (HIRE) Act.
- FBAR: Latest actions affecting compliance with Form TD F 90.22-1 and the new FATCA Sect. 6038D information return.
- Estate and gift taxes: 2010 tax suspensions followed by the return in 2011, and what that means for international business dealings and tax.
- Audit: Whether the beefing up of IRS international exam efforts will affect you.
Faculty

Brent Lipschultz
Partner
Eisner Advisory Group
Mr. Lipschultz has over 25 years of experience and is a leader in the firm’s International Wealth Planning Team.... | Read More
Mr. Lipschultz has over 25 years of experience and is a leader in the firm’s International Wealth Planning Team. He focuses on domestic and international income, and estate and gift tax planning for global investors, corporate executives, athletes and entertainers, and closely held business owners. Additionally, he advises global companies on expatriate tax and payroll matters and provides services in the areas of compensation planning and charitable giving. He has represented clients before the IRS and state taxing authorities on complex tax matters, including offshore voluntary compliance cases.
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Layla Aksakal
Counsel
Miller & Chevalier
Her work encompasses federal income tax planning and controversy in all aspects of corporate domestic and international... | Read More
Her work encompasses federal income tax planning and controversy in all aspects of corporate domestic and international tax including foreign tax credit utilization, Subpart F, acquisitions and dispositions, reorganizations, joint ventures, consolidated returns and outbound property transfers. She frequently represents clients before the IRS National Office.
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Peter Daub
Partner
Baker & McKenzie
He has more than 20 years of experience in international and domestic tax planning for U.S. and foreign... | Read More
He has more than 20 years of experience in international and domestic tax planning for U.S. and foreign multi-nationals, financial institutions and financial intermediaries. He previously worked as an associate international tax counsel for the Treasury Department, where he worked on foreign tax credit and Subpart F matters, among others.
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David Forst
Tax Group Practice Leader
Fenwick & West
Mr. Forst's individual practice specializes in international corporate and partnership taxation. He is a lecturer... | Read More
Mr. Forst's individual practice specializes in international corporate and partnership taxation. He is a lecturer on international taxation at Stanford Law School and a frequent writer on related topics.
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