A two-day primer with live group instruction on the fundamental U.S. cross-border tax rules for foreign income, persons and activities

Benefits of Attending

• Obtain a working knowledge of the basic international tax principles applied in the United States and in tax systems in other countries
• Learn how the U.S. international tax system operates and how companies and individuals become liable for U.S. income or withholding tax
• Find out the latest tax and business requirements in structuring foreign operations and activities
• Discover how the U.S. foreign tax credit mechanism operates and reduces your US tax liability dollar-for-dollar
• Learn how the Subpart F provisions terminate deferral of US tax on foreign profits and what you can do to prevent it
• Determine how your intercompany transactions are subject to scrutiny by the IRS and your tax exposure on audit
• FEATURING SPECIAL SESSIONS on U.S. withholding tax and key tax issues facing inbound investors
• Conference materials include a BNA Portfolio for all paid attendees

Educational Course Credit — Up to 16 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 Continental Breakfast

8:00 am Registration

8:30 am Chairman’s Introduction

8:45 am Fundamentals of International Tax

• Understanding territorial v. worldwide tax systems
   
• Residence v. activity-based taxing jurisdiction
   
• Avoidance of double taxation – exclusion and foreign tax credit
   
• Introduction to tax treaties and permanent establishments

9:30 am Understanding the U.S. International Tax System

• Definitions and source rules under Secs. 861-864 – statutory framework for the U.S. international tax provisions in the Code
   
• When is the income of a foreign corporation or nonresident alien subject to U.S. tax?
   
• What constitutes FDAPI and when is withholding required?
   
• U.S. international tax research – how to locate tax opinions, IRS pronouncements and new legislation

10:15 am Break for Refreshments

10:30 am Reporting the Results of Foreign Operations

• Obtaining the data from overseas for preparing and filing Form 5471 - key issues in reviewing Form 5471 for foreign affiliates
   
• Completing Form 8858 for foreign disregarded (CTB) entities
   
• Computing earnings and profits – reconciliation with financial statement retained earnings
   
• Review of key U.S. international reporting forms – Form 926, 1118, TD F 90-22.1 and 8838

12:15 pm LUNCHEON

1:30 pm Computing Foreign Tax Credit Benefits

• What constitutes a creditable income tax?
• Calculating foreign source taxable income, including expense apportionment under Reg. Sec. 1.861-8
   
• Understanding the overall and separate basket foreign tax credit limitations
   
• How to compute the FTC gross-up for dividends from foreign subsidiaries
   
• Treatment of overall foreign or domestic loss in determining FTC benefits

3:00 pm Break for Refreshments

3:15 pm Understanding the Subpart F Provisions

• Understanding the hopscotch effect of deemed dividends under Subpart F - planning for investments in U.S. property
   
• Applying the Subpart F rules to foreign activities of CFCs
   
• Treatment of previously-taxed income (PTI) on subsequent distributions and reorganizations
   
• Computing the U.S. tax on gain from the sale of stock in a CFC

5:00 pm Meeting Adjourns for the Day

Day Two

8:00 am Continental Breakfast

9:00 am U.S. Tax Aspects of Establishing a Foreign Corporation

• How to qualify an outbound transfer of assets to a foreign subsidiary or joint venture as tax-free under Sec. 367(a) – reporting the transfer on Form 926
   
• Special issues in acquiring a foreign corporation
   
• Organizing a foreign corporation or holding company – completing a Gain Recognition Agreement (Form 8838)
   
• Special issues involving liquidations, non-taxable mergers and reorganizations of CFCs

10:30 am Break for Refreshments

10:45 am Understanding the U.S. Transfer Pricing Regime under Sec. 482

• How U.S. companies today are expected to comply with the Sec. 482 arm’s-length standard – income shifting v. clear reflection of income
   
• When Sec. 482 applies in the international context – definition of related party and application to pass-through entities
   
• Finding a database for comparable profits methods
   
• Documenting intercompany sales for Forms 5471 and 5472

12:15 pm LUNCHEON

1:15 pm Complying with the U.S. Withholding Tax Regime

• U.S. withholding tax issues related to repatriation through FDAP-type payments (e.g. interest, dividends and royalties)
   
• Using management fee and Cost- Sharing Arrangement payments as a repatriation tool
   
• Interrelationship with U.S. tax treaty compliance
   
• Special issues in preparing FormsW-8BEN,W-8ECI, W-8EXP, or W-8IMY for reducing or exempting payments from U.S. withholding tax

2:15 pm Break for Refreshments

2:30 pm Source Of Income & Expense Apportionment Rules

• How U.S. Taxes Companies with Foreign Source Income
   
• Indentifying Foreign Source Income & Taxes-dividends, royalties and interest
   
• Tax Strategies For Apportioning Expenses & Foreign Source Income Factual v Gross to Gross
   
• Understanding the Special Apportionment Rules for interest & Research Expenses

4:30 pm Meeting Ends

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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