This webinar will discuss the U.S. limitations on interest deductions paid by multinational companies, thin capitalization restrictions imposed in other countries, and the OECD's recommendations for interest limitation rules. Our panel of international tax veterans will review Sections 163(j) and 26... Read More

This course will provide tax professionals with guidance on final and proposed regulations governing foreign source income taxation. The panel will present an in-depth analysis of changes in the application of Subpart F as a result of the TCJA, global intangible low-taxed income (GILTI), foreign-der... Read More

This course will provide a practical overview of the controlled foreign corporation (CFC) anti-deferral rules including the 2022 Section 958 final regulations that provide rules with respect to domestic partnerships and their partners. The panel will also discuss some key issues with respect to the... Read More

This webinar will explain the tax ramifications of creating, transferring, and holding intellectual property (IP) in the U.S. and overseas. Our panel of international tax experts will discuss appropriate holding entities, the U.S. international tax regimes as applied to IP, and transfer pricing cons... Read More

This webinar will review the relevant rules under the new quasi-territorial regime, the remaining types of untaxed foreign earnings, and the basics of Section 1248 and Section 245A. Our panel of multinational tax practitioners will explain planning strategies to use untaxed foreign earnings to recha... Read More

This webinar will identify the most frequent foreign entity structures encountered by U.S. international tax practitioners and their U.S. reporting requirements. Our panel of astute foreign tax professionals will divulge how these structures correspond with U.S. entity reporting structures, how they... Read More

This webinar will take an in-depth look at the categories of income reported on Form 1118 for the foreign tax credit. Our knowledgeable panel will explain how these baskets influence the ultimate calculation of the foreign tax credit, the allocation and apportionment of expenses by category, carryov... Read More

This course will provide a practical explanation of completing Form 1120-F, U.S. Income Tax Return of a Foreign Corporation. Our experts will explain how to properly prepare this onerous form, including who is required to file, filing protective returns, and issues for consideration with respect to... Read More

This course will explain the nuances of branch profits tax, including what entities are subject to this additional tax, how U.S. effectively connected income, dividend equivalent amounts, and the change in U.S. net equity is determined, and the effect of U.S. income tax treaties on the branch profit... Read More

This course will provide an analysis of the final regulations issued in December 2021 and discuss the preparation of Form 1118 for tax practitioners and advisers grappling with these calculations. Read More

This course will identify specific tax issues surrounding the sale of a foreign entity. Our panel of foreign tax veterans will explain steps that taxpayers can take to lessen the taxes paid when selling stock or assets held overseas, including critical elections. The panel will also review required,... Read More

This course will provide tax advisers with thorough and practical guidance on the advantages and pitfalls of utilizing the check-the-box election for foreign subsidiaries. The panel will discuss the various tax effects of specific elections, outline the tax timing and treatment, and explain repatria... Read More

This webinar will discuss the U.S. tax consequences of outbound asset transfers to foreign corporations. Our panel of international tax experts will explain the interplay of Section 367 with the nonrecognition rules, reporting responsibilities, and gain recognition agreements (GRAs) with the IRS for... Read More

This course will explore the tax difficulties faced by multinational companies with foreign subsidiaries. The panelist of veteran foreign tax professionals will discuss the compliance challenges these businesses face, including recent transfer pricing cases, Section 894(c) payments made by hybrid en... Read More

This course will highlight many areas where U.S. businesses make costly Canadian sales tax mistakes when selling goods and/or services into Canada. The panel will provide useful information to help corporate tax advisers avoid the most common costly mistakes. Read More

This course will provide corporate tax professionals and advisers to multinational corporations (MNCs) and other multinational businesses with a detailed, practical, and thorough guide to mitigating the risk of high tax levels on effectively connected income (ECI). The panel will provide practical g... Read More

This course will provide corporate tax advisers with a detailed and practical guide to Form W-8BEN. The panel will describe the most recent changes to Form W-8BEN. The webinar will offer useful tips to complete the form, including the treaty position references and issuing Form W-8 from the payor's... Read More

This course will provide tax managers and advisers with a roadmap for considering establishing a business in a foreign country with a low or no tax regime. Our panel of international tax experts will explain the latest regulations surrounding GILTI and the opportunities available to mitigate GILTI t... Read More

This course will discuss the final Section 250 regulations issued July 2020, including pointing out the many modifications made to the proposed regulations. Our panel of international tax experts will explain the mechanics of the calculations and provide hands-on examples of how the deduction is cal... Read More

This course will outline the caveats international tax professionals need to be aware of when working with buyers and sellers of multinational entities. Our panel of experts will explain the latest tax considerations of business combinations for multinational companies after the recent tax act. Read More

This course will position U.S. corporate tax professionals to more effectively comply with VAT reporting, withholding, and remittance requirements in Mexico when their companies either purchase goods there, sell to Mexican residents, or provide digital or other services in the country. Read More

This course will point out the issues of multinational employee compensation that tax professionals working with global businesses need to understand. The panel will discuss the caveats of sending workers to other countries, how to avoid or lower payroll and other taxes imposed in other countries, a... Read More

This course will discuss key issues regarding income tax and sales tax compliance obligations for entities doing business in Canada. The panel will outline issues that companies face when doing business in Canada, including a review of the Canadian system of taxation, reporting obligations that may... Read More

This course will provide professionals with a solid foundation on defining a controlled foreign corporation (CFC) and a "U.S. shareholder," under the rules of Subpart F. The panel will prepare corporate tax managers and advisers to master tax reporting challenges by drilling down into different type... Read More

This course will provide tax advisers and compliance professionals with a sound foundation for identifying the U.S. tax consequences and information reporting requirements of outbound transactions. The webinar will outline the anti-deferral regimes, rules for income sourcing, foreign tax credits, ap... Read More

This course will provide corporate tax advisers with a practical guide to claiming deductions of worthless stock in the context of controlled foreign corporations (CFCs) after the 2017 tax reform law. After briefly outlining the prior treatment allowing for a full deduction for worthless stock in a... Read More

This course will provide corporate tax advisers with a detailed and practical guide to the repatriation provisions of the Section 965 transition tax in the wake of the most recent IRS final regulatory guidance. The panel will discuss E&P and basis adjustments, foreign tax credit calculations, and sp... Read More

This course will furnish tax advisers with a thorough and practical guide to the reporting of investments in a passive foreign investment company (PFIC) on IRS Form 8621. The panel will identify those investments that require PFIC reporting, focusing specifically on the look-through rules that apply... Read More

This course will provide corporate tax advisers with a practical guide to identifying potential foreign information reporting noncompliance, and correcting and disclosing filing deficiencies. The panel will discuss the most common issues in completing international information forms such as the FBAR... Read More

This course will provide U.S. shareholders of controlled foreign corporations (CFCs) and their tax advisers with an overview of the previously taxed earnings and profits (PTEP) proposed guidance from Notice 2019-01. The panel will discuss the latest IRS guidance on ordering rules, detail the PTEP gr... Read More

This course will provide tax advisers serving clients with controlled foreign corporations (CFCs) with a detailed and practical guide to the new Section 163(j) business interest deduction limitation rules--part of the 2017 tax reform law--as they apply to foreign corporations and their U.S. sharehol... Read More

This course will prepare corporate tax executives and advisers with a useful survey of the reporting requirements for U.S. companies with cross-border structures. The panel will outline the significant changes and challenges to completing Forms 5471, 5472, 1120-F and 926 with practical experiences g... Read More

This course will provide tax advisers with a practical guide to calculating and reporting the Section 250 tax deduction for foreign-derived intangible income (FDII). The panel will go through the steps required to identify qualified business asset investment (QBAI) property, deduction-eligible incom... Read More

This course will provide corporate tax professionals with a practical guide to three recently announced IRS LB&I international compliance initiatives that will impact U.S. corporations with offshore holdings. The panel will discuss the IRS enhanced focus on offshore service providers, the FATCA accu... Read More

This course will offer tax advisers to foreign companies with a practical evaluation of the impact of the Supreme Court decision in South Dakota v. Wayfair on non-U.S. based sellers of goods and providers of services. The panel will discuss the ramifications of the Court's overturning of the physica... Read More

This course will provide corporate tax professionals with a thorough and practical guide to calculating and claiming the dividends-received deduction (DRD) for the foreign-source portion of dividends received from specified 10%-owned foreign corporations by domestic U.S. shareholders of those foreig... Read More

This course will guide tax professionals and advisers on tax challenges involving inbound asset transfers, cash dividends and other repatriation strategies post-tax-reform. The panel will discuss tax issues associated with inbound liquidations under Section 332 and reorganizations under Section 368,... Read More

This course will provide tax executives, tax counsel and tax advisers with a drill down into the intricacies of Foreign Account Tax Compliance Act (FATCA) compliance relevant to non-financial foreign entities (NFFES), including Chapter 4 withholding, NFFE status and potential exemption, new requirem... Read More

This course will provide corporate tax executives and advisers with practical guidance on short-term and long-term tax issues in selecting an entity for a foreign affiliate, subsidiary, etc. The panel will outline how to navigate the tax consequences inherent in foreign entity selection decisions. Read More

This course will furnish corporate tax managers and advisers with a comprehensive guide to the recently issued IRC 987 regulations for calculating and reporting taxable income and loss attributable to a foreign branch with a different functional currency than its owner. The panel will describe the n... Read More

This course will provide corporate tax professionals with a solid and practical guide to Form 1120-F. The panel will focus on the key schedules unique to Form 1120-F, discuss the permanent establishment rules, and offer useful guidance in filing protective returns and other strategies to avoid IRS a... Read More

This course will provide corporate tax professionals with a comprehensive guide to complying with reporting obligations for contributions of cash or other property to foreign corporations. The panel will identify the types of transactions that trigger reporting obligations, discuss filing thresholds... Read More

This course will provide corporate advisers with a practical and comprehensive guide to the tax and other implications of granting compensatory stock options to nonresident employees. Read More

This course will provide corporate tax advisers with a practical and comprehensive guide to planning and calculations related to the branch profits tax. The panel will detail steps needed to calculate the dividend equivalent amount (DEA) that constitutes the base for computing the branch profits tax... Read More

This CPE course will provide U.S. tax advisers and corporate tax executives with a practical guide to navigating the permanent establishment rules for foreign corporations conducting business in the United States. The panel will discuss the evolving standards for determining whether a foreign entity... Read More

This course will provide corporate tax professionals with a deep and practical guide to navigate the IRS processes for obtaining relief from penalties and deduction disallowances due to failure to accurately file Form 1120-F Income Tax Return of a Foreign Corporation. The panel will discuss the puni... Read More

This course will provide corporate tax professionals and advisers with a practical guide to the challenges and strategies of repatriating foreign income. The panel will outline circumstances in which companies would choose to repatriate, detail steps to minimize tax on repatriation transactions, dis... Read More

This course will provide corporate tax advisers with a broad and practical guide to foreign tax planning of outbound transactions. The panel will describe the various deferral structures allowed by the Internal Revenue Code, review the ownership and asset thresholds for "CFC" and "PFIC" status and d... Read More