Reconciling U.S.-Foreign Intercompany Accounts to Avoid Taxable Deemed Dividends Under Section 956
Recording of a 110-minute CPE webinar with Q&A
This course will provide corporate tax professionals with a deep dive into the complex and often neglected process of reconciling intercompany payables and receivables between a U.S. company and a controlled foreign subsidiary. The panel will discuss important but easily overlooked steps to properly record intercompany accounts to avoid negative tax consequences in the form of deemed dividends in cases where the accounts are not properly cleared.
- Intercompany receivables for U.S. parent company
- Avoiding deemed dividends
- Use of ERP systems
- Case study
The panel will discuss these and other important questions:
- Which accounts and transactions can trigger deemed dividends if not maintained?
- What are threholds for avoiding Section 956 deemed dividend treatment?
- How best to avoid substance over form issues?
- How to maintain intercompany balances to conform to Section 956 requirements?
Lewis J. Greenwald
Mr. Greenwald's practice is focused on providing international tax planning for multinational clients. He... | Read More
Mr. Greenwald's practice is focused on providing international tax planning for multinational clients. He counsels client on a variety of issues including, cross-border foreign currency transactions; tax efficient acquisitions, dispositions, reorganizations, and repatriations; migrating intellectual property to tax favored jurisdictions; avoidance of all types of subpart F income; leveraging operations, creating double deductions;debt/equity determinations; bad debt/worthless stock deductions; foreign source income generators;dual consolidated loss compliance and administrative relief; transfer pricing-planning, compliance, and controversy; and Individual US international tax compliance, voluntary disclosures, and expatriations.Close
William R. Skinner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.Close
Paul K. Marineau
Global Tax Consulting
Mr. Marineau is a Professor at Thomas M. Cooley Law School where he teaches International Tax–Outbound and... | Read More
Mr. Marineau is a Professor at Thomas M. Cooley Law School where he teaches International Tax–Outbound and International Tax–Inbound in the LL.M Tax Program. He also teaches taxation, corporate taxation, and taxation of business entities in the J.D. program. Previously, he was an international tax partner at Crowe Horwath LLP where he was the firm-wide practice leader for international tax services, firm-wide international liaison partner with Crowe Horwath International, and a member of the Crowe Horwath international tax executive committee.Close
Mr. Giardelli's practice is focused on international tax planning (including controlled foreign... | Read More
Mr. Giardelli's practice is focused on international tax planning (including controlled foreign corporations/Subpart F income, tax-efficient reorganizations, cross-border financing, IP planning, individual tax planning) and corporate tax matters, advising clients on the tax aspects of mergers, acquisitions, financing arrangements and other transactions.Close