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Blocker Structuring Under Current U.S. Tax Law: Key Considerations for U.S. Venture Funds...
June 17, 2021 CLE, CPE Live Webinar

This CLE/CPE webinar will provide tax counsel and private investment professionals with a practical guide to structuring investments by private equity and venture capital funds (PEVC funds) in a manner that seeks to address the various tax sensitivities of PEVC fund investors. Read More

Removing PFIC Taint on Foreign Investments Through Subsequent Year QEF Elections
New Final PFIC Regulations and Navigating PFIC Rules of IRC Sections 1291-1298
June 30, 2021 CLE, CPE, EA Live Webinar

This CLE/CPE webinar will provide tax attorneys and counsel with a practical guide to removing the "taint" of foreign investments treated as passive foreign investment companies (PFICs). The panel will discuss new final and proposed PFIC regulations, the complex qualified electing fund (QEF) electio... Read More

Structuring U.S. Trusts Classified as Foreign Trusts for Income Tax Purposes
July 15, 2021 CLE, CPE, EA Live Webinar

This CLE/CPE webinar will provide a deep dive into the planning opportunities and reporting requirements for U.S.-based trusts that must file as non-domestic trusts for income tax purposes. The panel will discuss what constitutes "substantial decisions by non-U.S. persons" for trusts, structuring co... Read More

Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance
Recognizing When the IRS Will Deem an International Tax Information Filing as Not "Substan...
June 8, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with a practical discussion of IRS International Practice Unit (IPU) guidance on what constitutes "substantial compliance" in filing Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. The panel will d... Read More

Section 385 Regulations on Related-Party Debt
Avoiding Reclassification of Debt to Equity, Structuring Intercompany Debt Instruments to...
June 3, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide critical analysis of the IRS regulations under Section 385 to reclassify certain related-party debt as equity for U.S. tax purposes. The panel will discuss the regulations' scope, examine what types of structures and transactions are subject to reclassification as e... Read More

Form 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abateme...
Establishing Reasonable Cause Exceptions, Appeals Prior to Payment, Collection Due Process...
May 20, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a comprehensive and practical guide to a deep exploration into the reporting regime for U.S. taxpayers' ownership of foreign trust assets on IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts... Read More

New IRS Audit Campaign for Puerto Rico Act 20 and Act 22 Grantees: Key Issues for Individu...
Managing IRS Examinations and Audits of Puerto Rico Act 60 (f/k/a Act 20 and Act 22) Benef...
May 4, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide persons who have claimed advantage of Puerto Rico Act 20 and 22 and their tax advisers with guidance on what to expect as a result of the new IRS audit campaign on grantees. The panel will also discuss the favorable treatment for Puerto Rico-source income and areas... Read More

Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the A...
April 20, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign information reporting forms, their as... Read More

U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulati...
Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Pro...
March 25, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e). Read More

Structuring Foreign Investment in U.S. Real Estate: Entity Selection and Transaction Struc...
FIRPTA, Determining Individual vs. Entity Ownership Structures, Achieving Optimal Tax Trea...
March 16, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. real estate. The panel will outline best practices for determining the purchasing entity and review tax planning opportunities in structuri... Read More

Taxation of U.S. Persons Owning Foreign Corporations: Strategies for Subpart F and GILTI I...
February 24, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide guidance to tax counsel and advisers on the implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law. The panel will discuss key tax provisions and regulations causing compliance issues for U... Read More

Maximizing the FDII Deduction for U.S. Exported Property and Services: Determining Foreign...
January 6, 2021 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers guidance on the rules and reporting requirements for Section 250 tax deduction for foreign-derived intangible income (FDII). The panel will discuss new IRS regulations, identifying deduction-eligible income (DEI) and foreign-derived deductio... Read More

Mastering Subpart F Tax Compliance: Key Reporting Requirements on Forms 5471 and 1118
December 3, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals an in-depth discussion of the challenges of reporting Subpart F income. The panelist will discuss the proper methods of determining the Subpart F income earned by U.S. persons that qualify as U.S. shareholders of controlled foreign corporations (CF... Read More

Tax Planning Issues for U.S. Expatriation: Minimizing the IRC 877A Exit Tax
Determining Covered Expatriates, Navigating the Mark-to-Market Tax on Unrealized Gains, Re...
November 18, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes. The panelist will discuss the impact of new tax law on expatriation planning techniques, critical challenges under Section 877A, and guidance... Read More

U.S. GILTI Anti-Deferral Rules and Tax Compliance: Reporting Issues, Navigating Forms 5471...
November 17, 2020 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global low taxed intangible income (GILTI). The panelist will discuss how GILTI is calculated and key tax GILTI reporting issues involving IRS Forms 5471,... Read More

Repatriation Tax Audits: Managing IRS Enforcement Actions and Strategies for Tax Professio...
Calculating Section 965 Inclusions, IRS Regulations, Cash vs. Non-Cash or Non-Liquid Asset...
November 4, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and professionals an in-depth analysis of the challenges of repatriation tax audits and techniques for handling IRS enforcement actions. The panel will discuss recent IRS initiatives and standards for the repatriation of foreign sourced income, calculati... Read More

New GILTI High-Tax Exclusion: Sections 951A and 954 Rules for Individual and Non-C Corpora...
Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GI...
October 22, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals with guidance on the challenges of the global intangible low-taxed income (GILTI) provisions under current tax law and the recent GILTI High-Tax Exception. The panel will discuss IRS final regulations and the high-tax exception, treatment of contro... Read More

Canadian Tax Planning for U.S.-Based Taxpayers: Key Challenges for Businesses
Canada-U.S. Tax Treaty, Tax Issues for Acquisitions or Financing Canadian Businesses, and...
October 13, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of Canadian tax considerations for U.S.-based taxpayers. The panel will discuss the Canadian tax system as applied to U.S. based taxpayers, doing business in Canada considerations, acquisitions and financing Canadian ope... Read More

FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, FBAR Defense Strategie...
September 24, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers a critical analysis of FBAR examination, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, IRS guidance and relief for certain taxpayers, and new cases with issues of first impression relati... Read More

Navigating the IRS Penalty Abatement Procedures for Foreign Information Reporting Noncompl...
Requesting Penalty Abatements for Failure to File Forms 5471, 5472, FATCA, and FBAR
September 17, 2020 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax attorneys and accountants with a detailed discussion of best practices for requesting abatements of IRS penalties due to failure to properly file required international information forms such as the FBAR, Form 8938, and Forms 5471 and 5472. The panel will discus... Read More

Pre-Immigration Tax and U.S. Investment Planning for High Net Worth Individuals
Navigating the EB-5 Investor Visa Program, Leveraging Tax Credits, and Avoiding Tax Traps
September 10, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with a comprehensive guide to the tax and investment planning challenges and opportunities for high net worth foreign clients seeking to immigrate to the United States. The panel will discuss strategies for minimizing the U.S. tax impact of... Read More

Tax Perils of Passive Foreign Investment Companies for U.S. Shareholders: Reporting Obliga...
PFIC Rules, Determining Company Status, Exceptions, Allocation of Income, Qualified Electi...
August 5, 2020 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will guide tax professionals and advisers on the tax challenges and reporting obligations of U.S. shareholders of passive foreign investment companies (PFICs) under current tax law. The panel will discuss key tax provisions impacting the reporting of income from PFICs by U.S. ta... Read More

Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency...
Key Reporting and Compliance Challenges, Protective Filings, Relief Under Rev. Proc. 2020-...
July 16, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will guide tax professionals and advisers on critical tax presence and residency issues for individuals and businesses stemming from COVID-19. Read More

Domesticating Individually Owned Controlled Foreign Corporations Under Current Tax Law
Restructuring CFCs for U.S. Taxpayers, Mitigating Tax Liability, Section 962 Election, Tra...
May 28, 2020 CLE, CPE CLE On-Demand, Download

This webinar will guide tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually owned controlled foreign corporations (CFCs) under current tax law. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investm... Read More

Income Tax Treaty Practice for Tax Counsel: Planning and Structuring Transactions to Maxim...
Understanding and Applying Key Tax Treaty Provisions and the Coming Changes
May 7, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a solid overview and explanation of key tax treaty provisions that tax counsel must master in structuring cross-border transactions. The panel will focus on individual, small business, and middle-market positions and will enable tax counsel to advis... Read More

Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, For...
Evolution of "Non-Willful" Standard, Identifying Compliance Issues, District Court and Cou...
April 30, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of effective methods and challenges in resolving international tax compliance issues and disputes. The panel will discuss critical tax compliance issues stemming from Forms 3520/3520-A and 5471, navigating FBAR assessmen... Read More

New IRS Foreign Tax Credit Regulations: Allocating Expenses, Assigning Foreign Taxes to In...
April 16, 2020 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide tax practitioners a critical analysis of the new IRS final and proposed regulations on foreign tax credits. The panel will discuss the impact of the final rules on tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes... Read More

New IRS Base Erosion and Anti-Abuse Tax (BEAT) Final Regulations
Sec. 6038A Reporting Issues, Application to Partnerships, Gross Receipts and Base-Erosion...
April 1, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax professionals and advisers with a practical guide to the recently issued IRS final regulations on the base erosion and anti-abuse tax (BEAT). The panel will discuss critical provisions of the new IRS final regulations, application to pass-through entities, deter... Read More

Nonresident Alien Tax Compliance: Challenges and Planning Techniques for Tax Professionals
Recent IRS Compliance Campaign, ECI vs. FDAP Income, Reporting Requirements, Exemptions, D...
February 20, 2020 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and compliance professionals guidance on the rules, reporting requirements, and available tax planning mechanisms for U.S. nonresident alien taxpayers. The panel will offer approaches for determining taxpayer classification, identifying and reporting inc... Read More

Voluntary Disclosure of Foreign Assets: Current Challenges for Noncompliant U.S. Taxpayers
Options for Compliance, Avoiding Penalties and Potential Criminal Prosecution
November 14, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide counsel and tax advisers with guidance on available options for reporting foreign assets of noncompliant U.S. taxpayers. The panel will discuss Foreign Bank Account Report (FBAR) requirements, alternative compliance options after the IRS' termination of the Offshore... Read More

Taxation of Foreign Pensions: Application of IRC 402(b) and Avoiding Penalties for Noncomp...
Tax Rules Governing Foreign Pension Accounts, Foreign vs. U.S. Qualified Plans, Use of Tax...
October 30, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and ERISA attorneys a detailed analysis of the tax rules governing foreign pension accounts, with a specific focus on avoiding penalties for noncompliance. The webinar will go beyond the basics to offer useful practice pointers on the application of IRC... Read More

IC-DISC and FDII: U.S. Export Incentives Post-Tax Reform, Pricing Commissions, and Structu...
Maximizing Tax Savings, Pass-Through Entities vs. C Corporations, Distributor Companies, a...
September 24, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with an advanced guide to structuring interest charge-domestic international sales corporation (IC-DISC) companies. The panel will go beyond the basics to address alternative and sophisticated structures (including agricultural co-ops), comm... Read More

International Tax Compliance: Navigating Tax Implications of Cross-Border Activities
Reporting and Filing Requirements, Guidelines on IRS Issue-Based Examinations, Audits and...
September 4, 2019 CLE, CPE CLE On-Demand, Download

This webinar will provide tax counsel and advisers with a practical discussion of the tax implications, reporting requirements of cross-border activities, and issue-based examinations of foreign activities of individuals and companies. The panel will review complex international tax issues associate... Read More

Foreign Entity Selection and Taxation: Avoiding Tax and Reporting Pitfalls of Foreign Stru...
Planning for U.S. Owners of Offshore Businesses, Treatment of Foreign Trusts and Other Ent...
August 27, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of the tax and operational impacts of foreign entity selection for individuals owning controlling interests in international businesses. The panelist will discuss the tax issues that arise in foreign entity selection, wi... Read More

Gain on Sales of U.S. Partnership Interests by Foreign Partners: New Sections 864(c)(8) an...
Determining and Reporting Gain on Effectively-Connected U.S. Source Income
June 4, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel will discuss new and significant changes to international taxation relating to the disposition of U.S. partnership interests own... Read More

Tax Issues in Inbound and Outbound Transactions: Utilizing Partnerships to Maximize Tax Be...
Avoiding Landmines Under Current Tax Law, Deal Structures, Special Allocations
May 30, 2019 CLE, CPE, EA CLE On-Demand, Download

This webinar will guide tax counsel and professionals on tax challenges and opportunities in utilizing partnerships for inbound and outbound transactions. The panel will discuss key provisions impacting inbound and outbound transactions under current U.S. tax law, effectively using partnerships in s... Read More

IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Tax Savings Po...
Navigating Applicable IRC Sections, Formation and Qualification Issues, and Capturing Maxi...
May 22, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with the guidance necessary to maximize the powerful tax benefits of the interest charge domestic international sales corporation (IC-DISC). The panel will review the complex requirements of applicable IRC sections, formation best practices,... Read More

Foreign Tax Credit Limitations Under Section 904: New IRS Regulations and Guidance for Tax...
Allocations, Apportionment, Limitations Under Section 904(b)(4), Impact of GILTI, Carryove...
May 14, 2019 CLE, CPE, EA CLE On-Demand, Download

This webinar will guide tax counsel with a critical analysis of new IRS proposed guidance on foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the new regulations, additional "buckets" of foreign income grouping, new allocation and apportionment rules,... Read More

FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets
Unraveling Foreign Asset and Income Reporting Obligations, Navigating Available Voluntary...
February 6, 2019 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide counsel and tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets, as well as assisting clients with developing programs that provide workable solutions. Read More

Avoiding Tax Pitfalls of New EU Directive Targeting Cross-Border Tax Planning Mechanisms
Mandatory Disclosures by Intermediaries, Reporting Requirements, Planning Techniques and M...
September 13, 2018 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will guide tax professionals and advisers on recent directives of the European Union (EU) regarding mandatory reporting obligations for intermediaries and taxpayers. The panel will discuss the implications of the EU directive on U.S. companies, required disclosures of tax arrang... Read More

IRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Ent...
Lowering U.S. Income Tax on Income From Eligible Foreign Entities by Electing Tax-Advantag...
December 5, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide tax advisers with guidance on the advantages and pitfalls of using the "check the box" election for foreign LLCs and disregarded entities. The panel will discuss the tax impact of specific elections of income from foreign disregarded entities, outlining tax timing and treat... Read More

New IRC 721(c) Regulations and Contributions to Foreign Partnerships
Remedial Allocations and Structuring Transfers to Foreign Partnerships to Ensure Gain Defe...
September 6, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a detailed and practical guide to the rules governing contributions by U.S. persons to "related foreign partnerships," particularly in the wake of new IRC 721(c) Treasury Regulations, which effectively end non-recognition treatment of partnership co... Read More

Advanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act In...
July 26, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide tax counsel and advisers with a thorough and practical guide to strategies for administrative challenges and defenses against penalty assessments for FBAR violations. The panel will contrast the penalty structures between FBAR and other foreign-related information filings a... Read More

Sales Transactions of Controlled Foreign Corporation Stock: Avoiding Tax Impact For Buyers...
Navigating Sections 338(g) Elections and 901(m) Limitations for Buyers and Section 1248 Re...
March 22, 2017 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide tax counsel with a practical guide to navigating the IRS rules governing sales transactions involving controlled foreign corporation (CFC) stock. The panel will discuss the IRC 901(m), limitations on foreign tax credit benefits of a Section 338(g) election for buyers of... Read More

The Panama Papers: Guidance for Tax Counsel to Mitigate Client Tax Penalties and Criminal...
Conducting Account Reviews to Identify Legal Exposures, Designing Disclosure Strategy, Lev...
July 26, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with guidance for clients with offshore holdings who may fall under the scope of the "Panama Papers" or similar disclosure of shelter holdings. The panel will discuss due diligence requirements and processes, disclosure strategies, Offshore... Read More

Foreign Financial Institution Reporting: Are You Ready for the 2016 FATCA Deadlines?
FFI Reporting Under Model II IGAs, Completing Due Diligence, Filing Form 8957 and More
February 3, 2016 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisers with a detailed guide to preparing and filing a Foreign Financial Institution (FFI) Agreement. The panel will describe the FFI designation in depth, outline the due diligence and reporting requirements of a participating FFI, and discuss the... Read More

Streamlined Offshore Voluntary Disclosure Program: Avoiding Aggressive Enforcement Regime...
Leveraging the New OVDP Process for Claiming Non-Willful Failure to File
June 2, 2015 CLE, CPE CLE On-Demand, Download

This CLE/CPE webinar will provide counsel and tax advisors with the tools necessary to navigate the IRS rules governing the extended 2014 Offshore Voluntary Disclosure Program (2014 "OVDP") to determine whether clients are eligible for the less arduous and punitive streamlined programs. Read More

IRS CCA 201501013: Navigating New & Heightened Scrutiny of Foreign Investment Fund Lending...
March 17, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel and advisors with the guidance necessary to survive IRS scrutiny in the context of foreign investment fund lending. The panel will cover in detail the application of the trade or business designation to foreign investment fund lending as well as effectiv... Read More

Leveraging Outbound Transfers of Corporate Stock and Other Property
Navigating Sect. 367 Gain Recognition Agreements and Sect. 6038B Regs in Cross-Border Tran...
March 4, 2015 CLE, CPE, EA CLE On-Demand, Download

This CLE/CPE webinar will provide guidance to counsel on the use of outbound transfers and the recently issued IRS rules impacting those transfers. The panel will discuss gain recognition agreement requirements and the reporting rules and offer best practices for leveraging outbound transfers. Read More

FATCA Duties for Withholding Agents: Navigating Complex Regulations and New IRS Guidance
Determining Withholdable Payments and Payees; Applying Grandfather Rules; Collecting Docum...
December 17, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will prepare tax advisors and counsel to understand and guide withholding agents in complying with FATCA and applying the latest IRS guidance. The panel will explain complex, intricate requirements including identifying withholdable payments and payees, meeting documentation require... Read More

2014 FATCA Regulatory Updates: Navigating the Intricacies of Latest IRS Guidance
Implementing Treasury and IRS Amendments for NFFEs; Determining FFIs and Payee Status; Com...
June 26, 2014 CLE, CPE, EA CLE On-Demand, Download

This CLE webinar will provide counsel with guidance necessary to navigate the intricacies of the latest IRS guidance on FATCA compliance. The panel will review new Treasury and IRS amendments for NFFEs, FFI and payee status definitions, intergovernmental agreements (IGAs), and withholding and report... Read More

Tax Challenges for Foreign Investors in U.S. Real Estate
Navigating the Legal Considerations of Acquiring, Owning and Disposing of U.S. Real Estate
May 29, 2014 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide real estate attorneys, tax counsel and advisors with a review of tax considerations for foreign investors in U.S. real estate. The panel will address challenges for foreign investors, including form of ownership and IRS reporting obligations. Read More

Final FATCA Deadline Looms: Preparing for Compliance and Implementation
Navigating Complex IRS Regulations for Reporting Foreign Assets and Making Foreign Payment...
October 29, 2013 CLE, CPE CLE On-Demand, Download

This webinar will discuss the information reporting and withholding requirements under the recently issued Foreign Account Tax Compliance Act (FATCA) regulations. The program will focus on the latest developments in two key areas: the obligation of U.S. taxpayers to report foreign accounts, and the... Read More

Latest FATCA Reporting and Withholding Developments for 2013
Navigating Complex Requirements for Reporting Foreign Assets
November 6, 2012 CLE, CPE CLE On-Demand, Download

This CLE webinar will discuss the Foreign Account Tax Compliance Act (FATCA) reporting and withholding requirements, including Form 8938 reporting and FATCA withholding obligations. Where relevant, the program will also review continuing Foreign Bank and Financial Accounts Report (FBAR) compliance c... Read More

Tax Challenges for Foreign Investors in U.S. Real Estate
Structuring Investments That Minimize Taxable Income and Capital Gains
October 2, 2012 CLE, CPE CLE On-Demand, Download

This CLE webinar will provide counsel with a review of tax considerations for foreign investors in U.S. real estate, outline best practices for determining the purchasing entity, and review tax planning opportunities in structuring the deal. Read More

Section 892 Income Tax Exemption for Sovereign Wealth Funds
Leveraging New Regulations to Avoid Taxation for Commercial Activities
May 1, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax law advisors with a review of pending tax rule changes affecting sovereign wealth funds and other foreign-controlled entities seeking private U.S. investments that won't endanger federal income tax exemption. The panel will offer approaches to avoid exemption-spo... Read More

Transfer Pricing for Worldwide Income: New Rules and Enforcement
Transfer Pricing New Rules and Enforcement
April 10, 2012 CLE, CPE CLE On-Demand, Download

This teleconference will provide tax counsel with a review of U.S. rules on transfer pricing, provide guidance on efficiently resolving Advance Pricing Agreement issues at the reorganized IRS, and evaluate the new cost-sharing regulations. Read More