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| Title: |
| Duration: |
2 days |
Description:
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This two-day seminar gives you a basic understanding of how U.S. practictioners as multinational companies can reduce corporate taxes.
Our expert faculty analyzes and explains the key international tax topics that are currently being exaimined by the IRS, then allows you to ask important questions and receive one-on-one training.
There is no pre-requisite or advance preparation for this seminar.
Agenda
DAY ONE:
8:30 am Registration and Continental Breakfast
9:00 am Overview of U.S. International Taxation, Source of Income and Expense Apportionment- Residence For Taxation
- Income From Single and Mixed Sources
- Establishing Foreign Title Passage-The Use of Incoterms
- Tax Planning to Create or Increase Foreign Source Income
- The Basic Rules of Allocation and Apportionment
- The Apportionment of R&E Expenses
- Asset Apportionment of Interest Expense
- The Apportionment of SG&A Expenses
- Apportionment of Other Expenses
- Tax Planning in Expense Apportionment
11:00 am Refreshment Break
11:15 am Tax Reporting Requirements of Foreign Operations- Form 5471 - Filing Requirements, Obtaining Data, Computing E&P, Reporting Subpart F Income and Other Transactions
- Form 8858 Filing Requirements for Foreign Disregarded Entities
- Form 8865 Controlled Foreign Partnerships
- Form 1118 U.S. Foreign Tax Credits
- Form TDF 90-22.1 Foreign Bank Account Reporting
12:45 pm Luncheon
1:45 pm The Foreign Tax Credit- Determining A Creditable Tax
- The Foreign Tax Credit Limitation Formula
- The Direct Credit
- The Deemed Paid Credit
- Foreign Tax Credit Baskets
3:15 pm Refreshment Break
3:30 pm Subpart F Income- The Determination of a Controlled Foreign Corporation
- Understanding Foreign Base Company Income
- Exceptions and Limitations to Subpart F
- Section 956 Investments in US Property
- Treatment of Previously Taxed Income
4:45 pm Question & Answers
5:00 pm Seminar adjourns for the day
DAY TWO:
8:30 am Continental Breakfast
9:00 am Passive Foreign Investment Companies- Classification-The Income Test And The Asset Test
- Exceptions To PFIC Status
- Consequences Of PFIC Status
- Tax Planning For PFICs
10:00 am Refreshment Break
10:15 am Transfer Pricing- Overview of Section 482-The Arms Length Standard
- Determining The Best Method for Sales Of Products
- What Companies Must Utilize CUP, Resale Price, or Cost Plus
- When CPM Applies-Factors Determining Comparability
- Preparing/Reviewing A Transfer Pricing Study
- Multi-Jurisdictional Use of a Transfer Pricing Study
11:30 pm Income Tax Treaties- The Essential Elements of Income Tax Treaties
- Business Profits and Permanent Establishments
- Qualifying For Treaty Benefits-Dealing With The Limitation On Benefits Provision
12:30 pm Luncheon
1:30 pm Earnings and Profits- The Importance of Earnings and Profits in International Tax
- The Steps in Preparing an Earnings & Profits Study
- Preparing a Computation of Earnings & Profits-Pre-1987
- Preparing a Computation of Earnings & Profits-Post-1986
- Common Earnings and Profits Adjustments
- Practical Issues Involved in Calculating Earnings and Profits
2:45 pm Question & Answers
3:00 pm Seminar Concludes
Who Should Attend
This course is for beginners to the international tax field but have a background in domestic corporate taxation such as tax managers, analyst, specialists, CPAs, tax attorneys and in-house counsel abd those wanting to refesh their knowledge. This seminar is transitional and non-transitional which is appropriate for both newly admitted attorneys and experienced attorneys.
Continuing Education Credits
Up to 15 CPE/CLE Credits
CPE Credits: Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. www.nasba.org
CLE Credits: Continuing Legal Education Credits will be sought by those who request it at the seminar. Each state will have final approval on the exact number of credits granted. Transitional and/or non-transitional continuing legal education is available depending on the level of seminar. Accreditation is pending until approved by each CLE board. CLE is an important aspect of our seminars and we want to make sure you receive the appropriate accreditation.
Accommodations
A limited block of rooms at a reduced rate has been set aside for attendees of our seminars. Please contact the hotel below and mention that you are attending under Networking Seminars in order to receive the discounted rate. Sleeping rooms are released one month prior to the seminar date. Your sleeping room is not included in your registration fee.
Philadelphia:
Crowne Plaza Hotel City Center 1800 Market St Philadelphia PA (215) 561-7500
Sofitel 120 South 17th Street Philadelphia PA (215) 569-8300
Cancellations/Substitutions
All cancellations must be received 5 business days prior to seminar date to receive a refund minus a $100 processing charge. You can send a substitute or you can also request a credit in full to attend another seminar. No refunds will be processed within 5 business days of the seminar. You would, at that point, receive a credit to attend another seminar. If you fail to attend or inform us of your cancellation, you will lose your opportunity to request a refund or credit for the seminar.
To view available dates and locations for our Introduction to International Tax - 1 Day Workshop, click here.
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| About The Provider: |
Networking Seminars organizes educational seminars and unique networking events on cutting edge information for the tax, legal, finance and accounting industries. We bring together an international community of professionals and industry experts to learn the latest news and informaton, exchange ideas, share experiences and cultivate new business relationships.
Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. We also offer CLE course credits and file with each state by those requesting credit at the seminar. |
| Price: |
$995.00 |
| More Info: |
Contact Us For More Information |
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Keywords For This Course: introduction to international tax, tax seminars, CPE training, international tax, CLE courses, tax training, CPA training, Source or Income, Expense Apportionment, Earnings & Profits, Foreign Tax Credit, Subpart F Income and Transfer Pricing.
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