A two and one –half day intermediate level course with live group instruction on the latest U.S. international tax issues facing multinationals doing business overseas

Benefits of Attending

• 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 25 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"

CITE's block of discounted sleeping rooms is limited - reserve your sleeping room early! We cannot guarantee rates or availability. A very limited block of rooms at a reduced rate has been set aside for CITE attendees. For conferences being held at local firm centers, hotel blocks have not been arranged and accommodations are at your own discretion

Day One - Overview

7:30 am Registration and Continental Breakfast

8:00 Chairman Introduction & Overview

8:15 Doing Business Overseas, Choice of Entities & Overlay of Treaties

9:30 Break for Refreshments

Doing Business Abroad in Branch or Partnership Form

9:45 International Joint Ventures & Partnerships

11:15 Dual Consolidated Loss Limitation

12:30 pm Luncheon

Doing Business Abroad in Corporate Form

1:15 Outbound Asset Transfers to a Foreign Corporation - Section 367(a) & (d)

2:30 International Mergers & Acquisitions

3:30 Break for Refreshments

3:45 Dispositions of Controlled Foreign Corporation Stock - Section 1248

Foreign Currency

4:45 Functional Currency Rules - 986-989

5:45 Seminar Adjourns for the Day

Day Two - Subpart F

7:30 am Continental Breakfast

8:00 Overview of Subpart F - Sections 951 & 959

9:15 Foreign Base Company Income - Section 954

10:15 Break for Refreshments

10:30 Subpart F Planning Issues in Supply Chain Management

11:45 Section 956 Investments in United States Property

12:45 pm Luncheon

Foreign Tax Credits

1:30 §§ 861-865 Income Sourcing& Expense Allocation

2:45 Break for Refreshments

3:00 Direct & Indirect Foreign Tax Credits

4:30 Section 904 Limitation

5:45 Seminar Adjourns for the Day

Day Three - Transfer Pricing

7:30 am Continental Breakfast

8:15 Overview - Transfer Pricing

9:30 Intercompany Services

10:45 Break for Refreshments

11:00 New Cost-Sharing Rules

12:30 pm Seminar Concludes

Bloomberg BNA | CITE Conference Registration - Page 1

There are 3 ways to register for a Bloomberg BNA | 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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