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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 17, 2020 CPE, EA Live Webinar

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... Read More

Foreign Investment in U.S. Real Estate: Reporting and Avoiding Withholding, Holding Struct...
February 3, 2021 CPE, EA Live Webinar

This webinar will explain the complexities of taxation and withholding on foreign investment in U.S. real property. Our panel of multinational tax veterans will focus on strategies to minimize taxation of these properties--whether held individually or through an entity--for tax practitioners working... Read More

Basics of Foreign Tax Reporting: Identifying Individuals' Filing Requirements
Inbound vs. Outbound Reporting Duties, Intersection Between Information Reporting and Inco...
October 29, 2020 CPE, EA CPE On-Demand, Download

This webinar will provide tax advisers and compliance professionals with a sound foundation for identifying foreign tax and asset information requirements for individual taxpayers. The webinar will identify reporting requirements, differentiate between inbound and outbound filing duties, and detail... Read More

U.S.-Australian Dual Taxation Issues: Superannuation Funds and the U.S.-Australia Income a...
December 3, 2020 CPE, EA Download

This webinar will provide tax advisers filing returns for clients taxed in both Australia and the U.S. with an explanation of reporting requirements and tax obligations in both countries. The panel will discuss treaty provisions, relief from dual taxation, residency determinations, and how to mitiga... Read More

International Tax Issues for Athletes and Entertainers: Residency, Tax Treaty Provisions,...
August 20, 2020 CPE, EA Download

This webinar will discuss ways to mitigate the tax burden for foreign athletes and entertainers. Our international taxation experts will discuss residency requirements along with structuring opportunities, tax treaty benefits, and withholding considerations for U.S. resident and nonresident performe... Read More

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... Read More

Sourcing U.S. and Foreign Income: Dividends, Service Income, Property Sales, Rents, and In...
July 8, 2020 CPE, EA Download

This webinar will provide a comprehensive review of how income is sourced to the U.S. and other countries. Our authoritative panel will provide insights to help mitigate multi-country taxation and avoid improper classifications of income. They will explain the benefits available in particular income... Read More

Global Entity Structuring: U.S. Taxpayers Doing Business Abroad
U.S. or Foreign, Corporation or Pass-Through, FTCs, Treaty Provisions and Relief Under 962
June 11, 2020 CPE, EA Download

This webinar will weigh the pros and cons of holding structure choices for foreign investments made by U.S. taxpayers. Our panel will explore the tax impact of entity choice as well as relief available for advisers working with taxpayers with global income. Description U.S. taxpayers are increas... Read More

Foreign Taxpayers and the CARES Act: NOL Carrybacks, PPP Loans, Permanent Establishment, F...
June 2, 2020 CPE, EA Download

This webinar will address the benefits available for foreign taxpayers under the CARES Act and the caveats of implementing this relief. Our international tax experts will explain the unique considerations of applying this relief to foreign individual and business taxpayers. Description The CARES... Read More

U.S. Foreign Tax Reporting for Individuals: International Repatriation and Inclusion Provi...
Section 962 Election, GILTI Inclusions, Intangible and Passive Income Treatment
May 14, 2020 CPE, EA CPE On-Demand, Download

This webinar will provide tax advisers and compliance professionals with a practical guide to the impact of the 2017 tax reform on U.S taxpayers with foreign income and tax reporting obligations. The panel will examine the significant changes the law imposes on calculating and reporting taxable fore... Read More

Nonresident Tax Issues: Effectively Connected Income, Structures for Holding U.S. Assets,...
May 21, 2020 CPE, EA Download

This webinar will provide tax practitioners working with U.S. nonresident aliens (NRAs) practical steps to minimize U.S. taxes for these U.S. taxpayers. The panelists will cover the rules for federal income, estate, and gift taxation of nonresidents and provide concrete advice on mitigating these ta... Read More

U.S.-UK Dual Taxation Pitfalls: Reporting Issues and Planning Opportunities for U.S. Taxpa...
Analyzing Tax Treaties to Minimize Tax: Impact of Brexit, Passive Income, and Pass-Through...
August 27, 2020 CPE, EA Download

This webinar will provide tax advisers with a thorough and practical guide into the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in the United Kingdom, as well as UK citizens with U.S. tax reporting obligations. The panel will discuss U.S. tax law... Read More

Trusts and Estates Foreign Asset Reporting: FATCA, FBAR, Forms 3520, 5471, and 8865
March 4, 2020 CPE, EA Download

This webinar will identify and explain the many required foreign reporting obligations, best practices for avoiding penalties, and how to resolve past noncompliance for trusts and estates. This webinar is for tax preparers, fiduciaries, and other professionals working with trusts and estates. De... Read More

Interpreting Tax Treaties: Tax-Free Interest, Foreign Tax Credits and Form 8833
January 16, 2020 CPE, EA Download

This webinar will provide tax advisers, professionals, and preparers with a solid overview and explanation of key income tax treaty provisions needed to determine whether their clients may take treaty-based return positions. The panel will discuss income tax treaties that exist between the U.S. and... 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

Basics of Foreign Tax Reporting: Identifying Individuals' Filing Requirements
Inbound vs. Outbound Reporting Duties, Intersection Between Information Reporting and Inco...
October 29, 2019 CPE, EA CPE On-Demand, Download

This webinar will provide tax advisers and compliance professionals with a sound foundation for identifying foreign tax and asset information requirements for individual taxpayers. The webinar will identify reporting requirements, differentiate between inbound and outbound filing duties, and detail... 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

Remedying Incorrect Section 965 Inclusions After Final Regulations
Determining How to Make Forward Adjustments to 965(h) Installment Amounts Absent IRS Guida...
August 21, 2019 CPE, EA Download

This webinar will provide tax advisers with a practical guide to remedying late or incorrect deemed repatriation filings required under Section 965 in the absence of detailed guidance from the IRS. The panel will describe recent IRS guidance offering relief from estimated tax penalties for failure t... Read More

U.S.-Mexico Dual Taxation: Residency Rules, Filing Requirements, Planning Opportunities
Tax Treaty Provisions, Center of Vital Interest Standards, Fideicomisos and Structures for...
July 18, 2019 CPE, EA Download

This webinar will provide tax advisers with a thorough and practical guide to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in Mexico, as well as Mexican citizens with U.S. tax presence and reporting obligations. The panel will discuss U.S. tax... Read More

International Private Client Issues for Non-U.S. Residents: Serving High Net Worth Foreign...
Foreign vs. Domestic Drop-Off Trusts, Working With Family Offices, Multi-Jurisdictional In...
May 30, 2019 CPE, EA Download

This webinar will provide tax advisers with a practical guide to the planning opportunities and potential tax pitfalls involved in providing private client services (PCS) for high net worth nonresident clients with U.S. tax presence. The panel will go beyond the basics to detail intricate strategies... Read More

Foreign Entity Selection for U.S. Owners of Offshore Businesses: Avoiding Tax and Reportin...
Applying U.S. Law to Foreign Structures, Determining Whether Foreign Trust Qualifies for U...
January 17, 2019 CPE, EA Download

This webinar will provide tax advisers to individuals owning controlling shares in foreign businesses with a practical guide to the tax and operational impacts of selecting the entity form for those foreign entities. The panelist will discuss the full range of short-term and long-term tax issues tha... Read More

Advanced Tax Planning for Nonresident Aliens: Pre-Immigration Strategies
Basis Adjustment Transactions, Drop-Off Trusts, Treatment of Nonresident Investment in the...
October 30, 2018 CPE, EA Download

This webinar will provide tax advisers with a practical guide to planning tools and techniques for clients who are nonresident aliens. The panel will go beyond the basics to detail intricate strategies for minimizing income tax, including basis strategies for non-U.S. situs assets, structuring "drop... Read More

Section 1291 Excess Distribution Calculations for PFIC Tax and Interest Reporting
Extrapolating PFIC Information From Fund Statements and Reporting on Form 8621
June 19, 2018 CPE, EA Download

This webinar will provide tax advisers with a detailed analysis of Section 1291 reporting including how to perform the onerous calculations and determine available elections to ease the burden. The panel will go beyond the basics to provide examples of PFIC disclosures on fund statements and illustr... 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

Removing PFIC Taint on Foreign Investments Through Subsequent Year QEF Elections
Navigating PFIC Rules of IRC Sections 1291-1298
August 1, 2017 CLE, CPE, EA CLE On-Demand, Download

This webinar will provide tax attorneys and counsel with a practical guide to removing the "taint" of foreign investments that are treated as passive foreign investment companies (PFICs). The panel will discuss the complex qualified electing fund (QEF) election rules, detailing the advantages, disad... Read More