Subpart F Income: Navigating the Revised Branch and Contract Manufacturing Rules
Recording of a 110-minute CPE/CLE webinar with Q&A
This teleconference will prepare corporate taxpayers and advisors to make informed decisions about taxability in situations involving foreign branch offices of a controlled foreign corporation or a contract manufacturing arrangement.
- Branch rules
- Broad terms of Sect. 954(d)2
- Final rules in T.D. 9563
- Guidance on application of branch rule, particularly to CFC with multiple branches
- Does CFC earn foreign base company sales income if purchases, sales conducted by multiple branches?
- If production activities conducted by multiple branches?
- IRS to continue to study when branch is separate Sect. 954(d)(2) corporation
- IRS to study relationship between foreign base company sales, and service, income
- Contract manufacturing regulations
- Framework for ensuring income of CFC operating as principal in contract manufacturing structure is not taxable in U.S. under general FBCSI or branch rules
- "Substantial contribution" test for manufacturing exception
- Practical taxability decisions and reporting issues
The panel will address these and other relevant topics:
- Material terms of the final branch office rules and associated IRS guidance.
- Key aspects of the contract manufacturing regulations.
- Practical decisions for taxpayers and advisors on taxability.
- Critical reporting issues.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Robert J. Misey, Jr.
Reinhart Boerner Van Deuren
Mr. Misey is attached to the firm's Tax and Business Law Practices, and chairs its International Practice. He... | Read More
Mr. Misey is attached to the firm's Tax and Business Law Practices, and chairs its International Practice. He works primarily on international taxation and tax controversies for clients in industries ranging from manufacturing to entertainment. He previously spent nine years with the IRS.Close
James K. Sams
Principal, International Corporate Tax
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical... | Read More
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical assistance and tax consulting to clients on inbound and outbound tax issues. He previously served in several roles with the IRS Office of Chief Counsel.Close
McDermott Will & Emery
His practice focuses on complex international tax matters for high-technology companies and other corporate clients.... | Read More
His practice focuses on complex international tax matters for high-technology companies and other corporate clients. He previously worked as a tax law specialist in the IRS Foreign Rulings Group, and is a frequent writer and speaker on international tax topics.Close