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CFC Worthless Stock Loss Deduction Rules: GILTI and BEAT Limitations to Deductibility of I...
December 17, 2019 CPE, EA Live Webinar

This webinar 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

Fundamentals of Corporate Foreign Tax: Outbound Taxation Boot Camp
Information Reporting Requirements, Anti-Deferral Rules, Income Sourcing, Discerning Globa...
January 15, 2020 CPE, EA Live Webinar

This webinar will provide tax advisers and compliance professionals with a sound foundation for identifying foreign tax and asset information requirements for corporate taxpayers. The webinar will outline the rules for income sourcing, distinguish between the various models for determining whether i... Read More

FDII Deduction and GILTI Rules: Claiming Section 250 Tax Incentives on Eligible Foreign In...
QBAI, Expense Allocations, Sale of Property Provisions, Deduction-Eligible Income, FDDEI T...
December 10, 2019 CPE, EA Download

This webinar will provide corporate tax advisers with a practical guide to the tax planning opportunities and challenges of the Section 250 FDII deduction in light of recent IRS guidance. The panel will discuss how the recently proposed regulations impact the treatment of certain transactions for pu... Read More

Section 965 Foreign Deemed Repatriation Transition Tax: Final Regulations
Identifying Cash Positions, Treatment of Consolidated Entities, Loss Treatments, Correctin...
November 26, 2019 CPE, EA Download

This webinar 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 s... Read More

Taxation of Foreign Source Income Under New Tax Law
Expansion of Subpart F, ยง245A D.R.D., Sales of CFC Stock, Tweaks to Ownership Attribution...
November 19, 2019 CPE, EA CPE On-Demand, Download

This webinar will provide tax professionals guidance on new rules and final and proposed regulations governing the taxation of foreign source income. The panel will present an in-depth analysis of the expansion of Subpart F, global intangible low-taxed income (GILTI), the territorial dividends recei... Read More

PFIC Identification and Reporting: Look-Through Attribution Rules, QEF and Mark-to-Market...
November 6, 2019 CPE, EA Download

This webinar 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 appl... Read More

Correcting Corporate Foreign Tax Noncompliance: Identifying and Repairing Incomplete or In...
Remaining IRS Voluntary Disclosure Initiatives, Challenging Finding of Willful Failure
October 29, 2019 CPE, EA Download

This webinar 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 FBA... Read More

Section 959 PTEP Categories and Ordering Rules for Controlled Foreign Corporation Distribu...
Notice 2019-1 New PTEP Groupings, Intersection of Section 959, 904 and 1248, Treatment of...
September 25, 2019 CPE, EA Download

This webinar 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 g... Read More

IRC 163(j) Interest Deduction Limits for Controlled Foreign Corporations: Planning & Calcu...
ATI Computation, CFC Group Election, Treatment of Tiered CFCs, Addback Rules
August 22, 2019 CPE, EA Download

This webinar 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. shareho... Read More

IRS Forms W-8BEN and W-9 Compliance After Tax Reform: New Information Requirements and ECI...
Withholding Agents' Certification and Withholding Duties in Foreign and U.S. Business Tran...
July 24, 2019 CPE, EA Download

This webinar will provide corporate tax advisers with a detailed and practical guide to Form W-8BEN. The panel will describe the most recent 2017 changes to Form W-8BEN and will offer useful tips to help complete the form, including the treaty position references and issuing Form W-8 from the payor'... Read More

Offshore Ownership Structures: Lessons Learned Under Tough IRS Scrutiny
Complying With Foreign Information Reporting Forms 5471, 5472, 1120F and 926
July 2, 2019 CPE, EA Download

This webinar 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... Read More

Subpart F vs. GILTI: Strategies for U.S. Companies After Tax Reform and New Foreign Tax Cr...
Planning Subpart F Inclusion to Use Excess Foreign Tax Credit Carryovers
June 18, 2019 CPE, EA Download

This webinar will provide corporate tax decisionmakers and advisers with a practical overview of the significant changes the 2017 tax reform law made to Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail the intersection of Subpart F with GILTI and the new propo... Read More

Canadian VAT Issues for U.S. Sellers: Goods & Services Tax and Harmonized Sales Tax Requir...
What are the Canadian sales tax traps for U.S. businesses?
May 30, 2019 CPE, EA Download

This webinar 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

FDII: Claiming New IRC 250 Foreign Derived Intangible Income Deduction on Form 8993
Determining Eligibility, Identifying QBAI and Deduction-Eligible Income (DEI), Calculating...
May 16, 2019 CPE, EA Download

This webinar 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 inco... Read More

New IRS Foreign Compliance Initiatives: FATCA Accuracy Exams, Offshore Service Providers,...
February 26, 2019 CPE, EA Download

This webinar 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 acc... Read More

New Economic Presence Nexus Standards for Foreign Remote Sellers: Impact of Wayfair Holdin...
Reporting and Remittance Duties on Offshore Entities, Marketplace Rules and Registration O...
February 5, 2019 CPE Download

This webinar 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 physic... Read More

Calculating Foreign Sourced Dividends-Received Deduction After Tax Reform
New Section 245A, Intersection of DRD Regime With Other Foreign Income Tax Provisions
January 8, 2019 CPE, EA Download

This webinar 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 forei... Read More

Repatriation Tax Planning: Inbound Asset Transfers, Cash Dividends and Other Strategies fo...
Tax Attributes Under Section 367(b) and Tax Reform Alterations, Deemed Dividends, Section...
October 30, 2018 CPE, EA Download

This webinar 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

Check-the-Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment Through...
Using Hybrid Entities for Tax Arbitrage, Structuring Entities to Enable Deferral of Foreig...
June 19, 2018 CPE, EA Download

This webinar 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 tax treatment, and explain r... Read More

New Section 59A: Base Erosion and Anti-Abuse Tax (the "BEAT")
Tax Benefit Limitations on Transactions and Other Challenges for U.S. and Non-U.S. Based M...
June 6, 2018 CPE, EA Download

This CPE webinar will provide tax professionals and advisers with an in-depth understanding of the base erosion and anti-abuse tax (BEAT) under Sec. 59A. The panel will discuss the strict rules, requirements and limitations of Sec. 59A for transactions between U.S. and non-U.S. affiliates and availa... Read More

Mastering FATCA Compliance for NFFEs: Navigating Who, What, When and How Much
Understanding the Complex Withholding Requirements
March 1, 2018 CPE, EA Download

This webinar 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 require... Read More

IC-DISC Compliance: Exporter Challenges in the Federal Tax Break
Leveraging Benefits From the Dividend Tax Solution
December 21, 2017 CPE, EA Download

This webinar will prepare tax professionals and advisers to leverage the tax benefits of IC-DISC formation. The panel will review and explain key steps for forming entities, tax planning and maintaining compliance. Read More

International Tax Impact of Business Entity Selection for Foreign Operations of U.S. Compa...
Making Tax-Based Decisions With Branch Offices, CFCs, Check-the-Box and More
December 12, 2017 CPE, EA Download

This webinar 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

New IRC 987 Regs and Foreign Currency Translation: Income Calculation for Qualified Busine...
November 30, 2017 CPE, EA Download

This webinar 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... Read More

Form 1120-F Reporting for Foreign Corporations: Filing Obligations Under IRS Scrutiny
Effectively Connected Income, Permanent Establishment and Treaty Position Exemption Claims...
October 10, 2017 CPE, EA Download

This webinar 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... Read More

IC-DISC Strategies Update: Commissions, Complex Computations, IRS Audit Risks, Tax Savings...
October 5, 2017 CPE, EA Download

This webinar will provide an updated guide to accounting professionals, tax advisers, and DISC administrators on the tax benefits and operational requirements of an Interest Charge-Domestic International Sales Corporation (IC-DISC). The panel will review and explain the key strategic steps for estab... Read More

Form 926 Compliance: Domestic Corporate Transfers to Foreign Subsidiaries and Related Corp...
Navigating IRC 6038 Corporate Rules for Transactions Involving Reorganization, Liquidation...
September 7, 2017 CPE, EA Download

This webinar 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 threshold... Read More

Subpart F Income Rules and Sections 956, 958 and 1248: Meeting the Reporting Challenges of...
July 13, 2017 CPE, EA Download

This webinar will provide professionals with a solid foundation on defining a controlled foreign corporation 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 types of... Read More

U.S. Equity Compensation Grants to Foreign Employees: Structuring and Reporting Options
Tax Impact of U.S.-Sourced Non-Qualified Options and Grants of U.S. Parent's Shares to For...
June 14, 2017 CPE, EA Download

This webinar 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

Branch Profits Tax Rules: Calculating and Reporting Dividend Equivalent Amounts and Identi...
Completing Form 1120-F Section III, Computing Tax on Excess Interest, and Planning to Mini...
May 10, 2017 CPE, EA Download

This webinar 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 ta... Read More

Mastering U.S. Permanent Establishment Tax Under New OECD Guidance vs. General Tax Treaty...
Navigating Income Attribution Rules in the U.S. Model Income Tax Convention and Recently S...
April 20, 2017 CPE, EA Download

This CPE webinar 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 entit... Read More

Navigating the Effectively Connected Income Tax Regime: Avoiding Devastating Impact on Tax...
Implementing Compliant Tax Strategies to Avoid or Mitigate Punitive Taxation
March 23, 2017 CPE, EA Download

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

Obtaining Relief From Form 1120-F Deficiency Penalties: Filing Protective Returns and Seek...
Preserving Expense Deductions, Claiming Treaty Positions and Leveraging Section 1.882-4 Pr...
February 14, 2017 CPE, EA Download

This webinar 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 pun... Read More

IC-DISC Strategies: Mastering the Complex Operational Challenges
Anticipating IRS Audit Risks, Calculating Commissions, and Tackling Computational Intricac...
November 10, 2016 CPE, EA CPE On-Demand, Download

This CPE webinar will prepare accounting professional, tax advisors, and DISC administrators to understand the requirements of Discs and to better leverage their tax benefits. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculatin... Read More

Repatriating Foreign-Source Income for U.S. Taxpayers: Minimizing the Tax Impact of Transf...
November 3, 2016 CPE, EA Download

This webinar 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, di... Read More

Check-the-Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment Through...
Using Hybrid Entities for Tax Arbitrage, Structuring Entities to Enable Deferral of Foreig...
October 20, 2016 CPE, EA Download

This webinar 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 impacts to specific elections, outlining the tax timing and tax treatment, both deferr... Read More

Mastering Foreign Tax Credits for Corporations and Individuals: Calculations, Carrybacks,...
September 7, 2016 CPE, EA Download

This webinar will provide tax advisers and corporate tax professionals with a comprehensive guide to the mechanics of the foreign tax credit in a global tax environment, including the rules, requirements, limitations, and opportunities for carryback, carryover and recalculation. Read More

Foreign Outbound Transaction Planning: Navigating Deferral Under Subpart F and the New IRC...
August 16, 2016 CPE, EA Download

This webinar 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... Read More

Income Sourcing in Multinational Tax Planning and Compliance: Navigating Residence Issues,...
July 7, 2016 CPE, EA Download

This webinar will provide tax professionals with a thorough understanding on how to identify the income-sourcing rules in international tax planning and compliance work; how to recognize the importance of both citizenship and residence in determining tax liabilities of individuals; and how to identi... Read More

New BEPS Country-by-Country Reporting Requirements: International Tax Reform Planning and...
Critical Steps for Multinational Companies to Take NOW to Prepare for New Transparency Sta...
June 2, 2016 CPE, EA Download

This webinar will provide a practical overview of the planning required as U.S. based multinationals transition to the new country-by-country reporting requirements and the increasing likelihood of international tax reform. The panel will identify entities impacted by the new reporting mandate, outl... Read More

Reconciling U.S.-Foreign Intercompany Accounts to Avoid Taxable Deemed Dividends Under Sec...
December 9, 2015 CPE, EA Download

This webinar 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 properl... Read More

European VAT for Cloud Computing, Software, Apps, and Other Digital Products and Services:...
August 4, 2015 CPE, EA Download

This webinar will update corporate tax professionals on the latest developments in value added tax (VAT) laws for companies that sell digital products and services to customers in the European Union (EU), and companies that purchase from EU-based business locations. The panel will offer approaches f... Read More

Mastering FATCA Compliance and Implementation for NFFEs: Navigating Who, What, When and Ho...
Understanding the Complexities of the Withholding Requirements
July 8, 2015 CLE, CPE, EA Download

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

Cross-Border Ownership Structures: Lessons Learned Under Tough IRS Scrutiny
Complying With Forms 5471, 5472, 1120F and 926
June 17, 2015 CPE, EA Download

This webinar will prepare corporate tax executives and advisors working on forms 5471, 5472, 1120-F and 926 with practical experiences geared toward improving compliance. The panel will provide insights to deal with IRS policies on audits and penalties. Read More

FBAR Requirements for Business Foreign Bank Accounts
Making Sound Compliance Decisions for Reporting Foreign Accounts Under Final IRS Regs
December 18, 2014 CPE Download

This webinar will bring corporate tax professionals and advisors up to speed on the most recent developments of the Report of Foreign Bank and Financial Accounts (FBAR) planning and reporting for companies and provide a detailed review of the reporting requirements under the FBAR program. Read More

IC-DISC: Compliance Challenges in the Federal Tax Break for Exporters
Leveraging Benefits Arising From the Dividend Tax Solution
October 21, 2014 CLE, CPE, EA CPE On-Demand, Download

This webinar will prepare tax counsel, professionals and advisors to take on the tough challenges of leveraging tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for forming entities, tax planning, and maintaining compliance. Read More

U.S.-Canada Corporate Tax Challenges With Surge in Cross Border Deals, More Aggressive Enf...
June 19, 2014 CLE, CPE Download

This webinar will provide tax professionals and counsel with a review, by an experienced panel of Canadian tax advisor/attorneys, of key recent and emerging corporate tax developments for U.S. companies. The panel will outline areas where U.S. and Canadian businesses must update tax compliance and p... Read More

Non-US Business Entity Selection - How U.S. and Global Taxation Regimes Impact the Decisio...
Making Critical Tax-Based Choices Regarding Branch Offices, CFCs, Disregarded Entities, Jo...
June 12, 2014 CPE Download

This webinar will provide tax executives and advisors guidance on the full range of short-term and long-term tax issues that arise in selecting the entity type to use for a new foreign operation and pitfalls to avoid if seeking to change the entity type after formation. The panel will outline how to... Read More

FATCA Compliance and Implementation for FFIs: Mastering the Complexities Before the July 1...
March 20, 2014 CPE Download

This webinar will discuss the information reporting and withholding requirements under the newly released FFI agreement under the Foreign Account Tax Compliance Act (FATCA) regulations. The program will focus on the latest developments, changes from the proposed agreement released in Oct. 2013, and... Read More

Leveraging Earnings-Stripping Regs for Foreign Investments: Maximizing Tax Savings, Minimi...
February 6, 2014 CPE Download

This webinar will provide tax professionals and advisors with an in-depth analysis of Sect. 163(j) regulations and guidance, explore frequently faced decisions involving interest deductions, and outline key strategies. Read More

Subpart F Income Taxation: Latest Compliance Developments
Mastering Income Calculation, Tax Rates, Audit Preparation and Other Complexities
December 18, 2013 CPE Download

This webinar will provide tax advisors with an analysis of the relevant terms of Subpart F and guidance in the context of practical situations frequently faced in U.S. federal income tax compliance, reporting and audits. Read More

Branch Profits Tax: Compliance and Planning from the Ground Up
Navigating the Tax Landscape for Foreign Businesses Operating in the U.S.
May 2, 2013 CPE Download

This teleconference will give tax advisors and federal tax professionals a detailed review of the branch profits tax, reported on Form 1120F. The panel will also cover other tax issues imposed on inbound activities of foreign businesses that are involved in a U.S. trade or business. Read More

Final FATCA Regulations: Implications for U.S. Taxpayers
Leveraging Benefits for Taxpayers Holding Assets in Offshore Financial Institutions or Oth...
March 28, 2013 CPE Download

This teleconference will give tax advisors and corporate federal tax professionals a detailed review of the final IRS Foreign Account Tax Compliance Act (FATCA) regulations issued in January and how they affect preparation of Form 8938. Read More

Outbound Transactions and U.S. Federal Tax
Tackling Compliance Challenges for U.S. Companies With Foreign-Based Income or Business Re...
January 15, 2013 CPE Download

This teleconference will give corporate tax professionals and advisors a review of essential federal tax issues affecting outbound transactions and explore difficult aspects that frequently arise in preparing related IRS forms. Read More

Inbound Transactions and Federal Tax: Compliance Issues With 1120-F, 8833 and Other Forms
Tackling Protective 1120-Fs, Calculation of ECI and FDAP, Exemptions and Other Challenges
December 5, 2012 CPE Download

This program qualifies for CPE and CFP continuing education credits. This teleconference will provide advisors and tax professionals with a review of the essential aspects of taxable income in the U.S. for foreign taxpayers, and explore complications that often arise in preparing the related IRS fo... Read More

Form W-8IMY: Preparing for Expanded Reporting of U.S. Withholding
November 7, 2012 CPE Download

This teleconference will provide corporate tax specialists with a detailed review of the planned major update to Form W-8IMY and prepare them to comply with pending changes to forms W-8BEN-E, W-8ECI and W-8EXP. Read More

Advanced VAT Issues for U.S. Corporate Tax Departments
Meeting Challenges With Accounting Systems, Refund Timing, Tax on Warranty Contracts and M...
September 6, 2012 CPE Download

This teleconference will provide tax managers a review of a discrete list of the higher-complexity VAT issues for U.S. companies in common tax administration and business activities. The panel will discuss internal company matters and relationships with taxing authorities and explore possible respon... Read More

Subpart F Income: Navigating the Revised Branch and Contract Manufacturing Rules
June 20, 2012 CLE, CPE Download

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. Read More

New Foreign Tax Credit and FTC Splitting Regulations
Mastering Section 909 and 901 Rules to Maximize Efficiencies in Complex FTC Planning
May 3, 2012 CLE, CPE Download

This teleconference will provide tax professionals with a review of the temporary Sect. 909 and final Sect. 901 regulations involving foreign tax credits and foreign taxpayers. The panel will explore how the regs affect U.S. corporate taxpayers' compliance and planning in a variety of FTC structures... Read More