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

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Conducted on Wednesday, January 5, 2011

Recorded event now available

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Course Materials

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.


A number of important developments in 2010 at the federal legislative and regulatory levels should alert tax professionals to reexamine tax planning assumptions and approaches, both from a corporate and family owned business/high-net-worth individual perspective.

For example, H.R. 1586 imposed significant new restrictions on use of foreign tax credits and eliminated the 80/20 test for withholding. The HIRE Act imposed a 30% withholding tax on income from U.S. financial assets held by many foreign financial institutions and the new FATCA 6038D info form.

Add to that, developments with the revised FBAR (Form TD F 90.22-1); the scheduled end to the 2010 suspension of the federal estate tax, which factors into structuring of international investments; and the planned tripling of IRS international examiners. Staying current is a challenge.

Listen as our panel of seasoned tax advisors addresses key U.S. foreign tax developments in 2010 in the context of possible changes to tax planning.



  1. Relevant U.S. legislative changes
    1. Education Jobs and Medicaid Assistance Act of 2010, H.R. 1586
      1. International tax extenders shifted from separate tax extender bill onto this legislation
      2. Prohibition against foreign tax credit-splitting
      3. Denial of foreign tax credits for disqualified portion of foreign tax paid on covered asset acquisition
      4. Repeal of 80/20 rules for interest paid and U.S. withholding
      5. Other aspects
    2. HIRE Act, H.R. 2847
      1. New international tax reporting requirements
      2. Withholding on income from U.S. financial assets held by foreign financial institutions
    3. Possible upcoming legislation
      1. After recess, Congress was to consider look-through treatment of payments between related CFCs
  2. Ongoing compliance challenges
    1. FBAR issues and new FATCA 6038D form
    2. Other new federal forms
    3. Estate and gift tax issues
      1. Estate tax suspended in 2010, scheduled to return in 2011 with lower exemption
      2. Effects on international structures
    4. IRS audit treatment of international structures
      1. Adding many more examiners
  3. Adjustments to international tax planning to consider, in light of these and other developments


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.


Lipschultz, Brent
Brent Lipschultz

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

Layla Aksakal
Layla Aksakal

Miller & Chevalier

Her work encompasses federal income tax planning and controversy in all aspects of corporate domestic and international...  |  Read More

Peter Daub
Peter Daub

Baker & McKenzie

He has more than 20 years of experience in international and domestic tax planning for U.S. and foreign...  |  Read More

David Forst
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

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