A two and one-half day technical update with live instruction on the latest U.S. international tax strategies for U.S. multinationals

Benefits of Attending

• Learn how the 2010 Obama tax legislation can affect international tax planning at your company in 2010
• Determine the most tax-efficient vehicles for investing overseas
• NEW TOPIC - Understand how foreign exchange gain (loss) is computed for cross-border operations
• Discover U.S. tax recapture consequences of a dual consolidated or branch loss and an overall foreign or domestic loss
• Understand the latest IRS rules under Sec. 987 for taxing payments between foreign corporate disregarded entities
• Learn how to compute foreign tax credit benefits for separate basket income using look-through rules
• Find out the latest interest and R&D expense apportionment rules for foreign tax credit and domestic production activities
• Understand the latest changes to the Subpart F branch rules and investments in U.S. property
• Planning for the migration of intangibles and implementing a cost-sharing agreement under the latest IRS regulations
• Ascertain how a cross-border merger or acquisition can trigger gain recognition and affect future distributions from the foreign target
• Determine the U.S. tax consequences of selling CFC shares under the Sec. 1248 recharacterization rules
• NEW TOPIC ADDED! Disclosure of Uncertain Tax Positions

Educational Course Credit — Up to 20 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

8:00 am Registration and Continental Breakfast

8:30 am CITE Introduction and Overview

8:45 am Reporting the Results of Foreign Operations and Activities

• What constitutes a controlled foreign corporation (CFC) and who is required to file Form 5471? – categories of filers
   
• Understanding the functional currency concept of QBUs – translation of income and B/S items, E&P and foreign taxes
   
• Preparing Form 5471 – analyzing the income statement and balance sheet for Subpart F and transfer pricing adjustments
   
• Tracking Earnings & Profits on Form 5471 for foreign dividend and gross-up calculations

10:15 am Break for Refreshments

10:30am Complying with the IRS Rules for Intercompany Transactions

• Preparing an economical Transfer Pricing Study - avoiding penalties under Sec. 482 – using an APA to provide certainty
   
• Computing the arm’s-length profit on related party sales – determining the Best Method - impact of the “first sale” rule
   
• Understanding the new intercompany service regulations - charging for headquarter services and imbedded intangibles
   
• Migrating intangibles to an offshore licensing vehicle – implementing a qualified cost-sharing arrangement
   
• Collateral U.S. tax consequences of a Sec. 482 audit adjustment – interrelationship with FIN 48 for tax accounting purposes

12:15 pm LUNCHEON

1:00 pm Computing Direct and Indirect Foreign Tax Credit Benefits

• Obtaining foreign tax credit benefits for foreign withholding taxes – what constitutes a creditable income tax
   
• How the gross-up formula for foreign taxes is applied
   
• Computing the foreign tax credit limitation under Sec. 904
   
• Understanding how separate foreign tax credit basket limitations are computed in 2009 - separate limitation loss recapture
   
• Applying the related party look-through rules for dividend and interest payments between related CFCs and 10/50 entities
  

2:30 pm Break for Refreshments

2:45 pm Expense Apportionment Update

• How expense apportionment can affect your ability to credit foreign taxes and deduct U.S. expenses
   
• Selecting the best apportionment method - gross-to-gross v. factual apportionment
   
• Understanding the new rules for interest apportionment – affect of exchange rates on foreign asset bases
   
• Strategies for minimizing the apportionment of research, state tax and S,G&A expenses to foreign source income

4:00 pm 2010 New Tax Changes Effecting Executives and Individuals

• Estate tax changes
   
• New individual tax rules
   
• New tax surcharges
  

Meeting Adjourns for the Day

Day Two

8:00 am Continental Breakfast

8:45 am How the Subpart F Anti-Tax Deferral Rules Operate

• Definition of U.S. shareholder - vote or value ownership
   
• Understanding the latest regulations involving Subpart F FPHC income - working with the branch rules for foreign sales and manufacturing activities
   
• Exceptions and limitations on application of the Subpart F rules – new regulations for hybrid branches
   
• Affirmative use of Subpart F - avoiding investments in U.S. property by first or lower-tier CFCs
   
• Treatment of previously taxed income under Sec. 959
  

10:30 am Refreshment Break

10:45 am Structuring Foreign Disregarded or Check-the-Box (CTB) Entities

• Choosing the right vehicle for investing overseas - branch v. corporation v. hybrid entity
   
• Understanding the CTB rules for foreign entities – planning for S corporations or LLCs
   
• Reporting transactions involving branches and foreign disregarded entities – computing Sec. 987 gains/losses – new Form 8858
   
• Translation v. transaction gain (loss) – determining the functional currency for foreign entities under Sec. 985
   
• U.S. tax consequences of dual consolidated losses – new rules for overall U.S. or foreign losses

12:15 pm LUNCHEON

1:15 pm Understanding the Rules for Computing Foreign Exchange Gain (Loss)

• Translation v. transaction gain (loss) – determining the functional currency for QBUs under Sec. 985
   
• Determining the character and source of Sec. 988 transactions – analysis of Schering-Plough case and taxation of derivative products
   
• Translation rules for foreign taxes and earnings and profits under Sec. 986
   
• Computing foreign exchange gain (loss) on remittances involving branches and foreign disregarded entities under Sec. 987

3:00 pm Refreshments Break

3:15 pm Interrelationship with the Tax Accounting Rules (FAS #109)

• Computing the tax provision v. tax liability for the year
   
• Analyzing deferred foreign taxes – applying APB #23 for permanently reinvested foreign earnings
   
• Calculating the U.S. tax cost on dividends of foreign earnings – treatment of excess direct and indirect foreign tax credits
   
• Determining the U.S. tax consequences of foreign check-the-box elections and merger and acquisition activities
   
• Interrelationship with the FIN48 rules for recognizing taxes attributable to a contested tax position
  

5:00 pm Meeting Adjourns for the Day

Day Three

7:30 am Continental Breakfast

8:00 am Corporate International Tax Compliance - 2009

• Obtaining the data from overseas for preparing and filing Form 5471 - key issues in reviewing Form 5471 for foreign affiliates
   
• Review of key U.S. international reporting forms – Form 926, 1118, TD F 90-22.1 and 8838
   
• E-filing issues for international operations – new Form 8858 for CTB entities
   
• Preparation of Form 8886 and Schedule M-3 for reporting significant book-tax differences
  

9:00 am Taxable Transfers of CFC Stock by U.S. Shareholders

• Computing the U.S. tax on gain from the sale of shares in a foreign corporation under Sec. 1248
   
• Obtaining foreign tax credit benefits on sales of shares in first and lower tier CFCs - consequences of making a Sec. 338 election
   
• Comparison of the Sec. 1248 tax consequences of a sale of subsidiaries v. pre-sale repatriation of profits

10:15 am Break for Refreshments

10:30 am Tax-Free International Mergers and Acquisitions under Sec. 367

• Evaluating the use of the new statutory merger or consolidation rules for an acquisition of foreign tangible and intangible assets
   
• Application of Sec. 367(a) to the incorporation of a new foreign company
   
• GRA reporting and compliance requirements for international mergers and reorganizations– substitution principles under recent regulations
   
• Conducting tax due diligence – negotiating tax representations and warranties

12:15 pm Meeting Ends

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