IRS Forms W-8BEN and W-9 Compliance: New Information Requirements and ECI Rules
Withholding Agents' Certification and Withholding Duties in Foreign and U.S. Business Tran...
January 21, 2021 • CPE, EA • Live Webinar
This webinar 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...
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Using Offshore Entities: Pros and Cons, Entity Selection, Treaty Benefits, GILTI vs. Subpa...
GILTI High Tax Exception Regs, Section 250 Deduction, Section 962 Election of Corporate Ta...
December 16, 2020 • CPE, EA • Download
This webinar 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...
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IC-DISC Strategies: Mastering the Complex Operational Challenges
Anticipating IRS Audit Risks, Calculating Commissions, and Tackling Computational Intricac...
November 10, 2020 • CPE, EA • Download
This webinar will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculating commissions, spotting IRS audit risks, and tackli...
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Final FDII and Section 250 Regulations: Substantiation Standards, Digital Sales, and Retro...
Mechanics of Calculating the Deduction: Determining FDII, DII, DEI, FDDEI, and QBAI
November 5, 2020 • CPE, EA • Download
This webinar 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 ca...
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Subpart F vs. GILTI: Strategies for U.S. Companies, Foreign Tax Credit Rules, New GILTI Hi...
Planning Subpart F Inclusion to Use Excess Foreign Tax Credit Carryovers
August 18, 2020 • CPE, EA • Download
This webinar will provide corporate tax decisionmakers and advisers with a practical overview of Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail the intersection of Subpart F with GILTI and the foreign tax credit regulations, and describe strategies in which...
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Fundamentals of Corporate Outbound Taxation: Boot Camp
Information Reporting Requirements, Anti-Deferral Rules, Income Sourcing, Discerning Globa...
January 15, 2020 • CPE, EA • Download
This webinar 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, a...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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.
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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.
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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.
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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.
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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.
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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...
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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.
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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.
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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.
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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.
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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...
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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...
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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...
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