A two-day technical update session with group live instruction offers the latest information on U.S. tax issues affecting the earnings and profits of CFCs

Benefits of Attending

• Overview of Earnings & Profits
• Earnings & Profits Details
• Determining Earnings & Profits of a Foreign Branch
• E &P and Subpart F Income
• Repatriation Planning Cases, Rulings, and Other New E&P Developments
• E &P After Spin-Offs, mergers and Acquisitions
• Earnings & Profits and Section 304 Transactions
• Managing E&P with Accounting Methods

Educational Course Credit — Up to 15 CPE / CLE Credits Available

Substitutions/Cancellations

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 1-914-328-5656, or e-mail info@citeusa.org. Credits will not be issued for "no shows"

Day One

7:30 am Registration and Continental Breakfast

8:45 Welcome & Chairman Introduction

9:00 Overview of Earnings & Profits

• Determining Status of Distributions
  
• Subpart F Income Limitation
  
• Calculating Deemed Paid Foreign Tax Credits
  
• Section 898 Current & Proposed Rules
  
• Determining PFIC Inclusions
  
• Form 5471

10:15 Break for Refreshments

10:30 Earnings & Profits Details

• Elections Sections 964, 338
  
• Baskets [Current & Proposed Section 904 Rules]
  
• E&P Pools & Translating Foreign Taxes
  
• Converting to the Euro
  
• Effect of Deficits on Baskets & Pools
  
• Pre-1987 Losses Carried Over
  
• Post-1986 Losses Carried Back
  
• Inheriting E&P From a Merger or Liquidation
  
• Nimble Dividend Rule
  
• Discussion of Current & Proposed Section 902 rules
  
• Complex Section 902 Example

12:30 pm Luncheon

1:30 Determining Earnings & Profits When a Foreign Company Has a Branch

• Translating the Branch’s Income and Expenses Under Section 987
  
• Calculating the Exchange Gain or Loss
  
• On Branch Remittances and When the Branch is Terminated
  
• Check-the-Box Branch Issues
  
• Application of the Hybrid Branch Regulations

2:30 Earnings & Profits and Subpart F Income

• Example Illustrating the Recapture and Rebasketing of Profits After a Deficit Has Limited Subpart F Inclusions
  
• Nimble Dividend Rule Examples
  
• Examples of the Subpart F Branch Income Effective Tax Rate Calculations
  
• High Tax Exception Example Calculation
  
• Previously Taxed Income Focusing on:
• Own PTI
• Inherited PTI
• Acquired PTI
• Section 959 Ordering Rules
  
• Exchange Gain or Loss on Distribution of PTI Example Calculation

3:45 Break for Refreshments

4:00 Repatriation Planning

• Using Section 956 Affirmatively
  
• Moving Cash Via Section 304
  
• Reorganizations and Cash Movements
  
• Other Non-Dividend Repatriation Techniques

5:30 pm Question & Answer Session

5:45 pm Seminar Adjourns for the Day

Day Two

7:30 am Continental Breakfast

8:45 Cases, Rulings, and Other New E&P Developments

10:15 Break for Refreshments

10:30 Earnings & Profits After Spin-Offs, Mergers and Acquisitions

• Calculating E&P After a Section 355 Spin-Off
  
• Applying the Section 367(b) E&P Regulations to Reorganizations,  Mergers and Acquisitions
  
• Planning Tips
  
• Example Calculations

12:00 pm Luncheon

1:00 Earnings & Profits and Section 304 Transactions

• When does Section 304 Apply
  
• Mechanics of Section 304
  
• Rev. Ruled 92 - 86
  
• Effect of E & P on Dividends
  
• Check the Box Issues

2:15 Managing E&P with Accounting Methods

• Impact of Accounting Methods on E & P
  
• Timing of Recognition of Income & Expense Deferral Options
  
• Adopting & Changing Methods

3:15 Question & Answer Session

CITE Conference Registration - Page 1

There are 3 ways to register for a CITE Conference:

1. Complete this form and fax Page 2 to 914-328-5757
2. Call us directly at 914-328-5656
3. Complete the online registration process

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