A two-day introduction and update session with live group instruction on the practical U.S. tax issues in documenting and reporting the tax and accounting results of foreign entities and operations

Benefits of Attending

• Find out how companies obtain foreign tax data from affiliates overseas for preparing Forms 5471
• Discover how to report the results of check-the-box and other foreign disregarded entities on new Form 8858
• Ascertain how to satisfy the tax reporting requirements under Secs. 367 and 1248 for foreign mergers and reorganizations
• Learn how to compute the amount of tainted Subpart F earnings and file an election to exclude Subpart F amounts
• Review the preparation of Form 1118 and how to prepare worksheets for computing earnings and profits (E&P) and the amount of indirect credit (Sec. 78) gross-up
• Understand how the expense apportionment rules under Reg. Sec. 1.861-8 affect foreign tax credit benefits
• Find out recent trends in transfer pricing planning and managing cross-border audits in multiple tax jurisdictions

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"

Dallas - The Westin Galleria 13340 Dallas Parkway Dallas, TX 75240 Tel: (972) 934-9494 Web: Westin Galleria Hotel Dallas Limited Time Reduced Room Rate: $159.00 single/double per night

Chicago - The Allerton Hotel 701 North Michigan Ave Chicago, IL 60611 Tel: (312) 440-1500 Web: Allerton Hotel Book Online: CITE Group Reservations Limited Time Reduced Room Rate: $185.00 single/double per night

Salt Lake City - Grand America Hotel 555 South Main Street Salt Lake City, UT 84111 Tel: (800) 621-4505 Web: Grand America Hotel Limited Time Reduced Room Rate: $209.00 per night

St. Louis - Renaissance St. Louis Grand Hotel 800 Washington Ave St. Louis, MO 63101 Tel: 314.418.5820 Web: Renaissance St. Louis Grand Hotel Limited Time Reduced Room Rate: $129.00 per night

Times/Topics Subject to Change

Day One

8:00 am Registration and Continental Breakfast

8:30 am CITE Welcome and Introduction

8:45 am Reporting the Results of Foreign Corporations

• When is a foreign corporation required to file a return with the IRS? - Form 5471
  
  
• Preparation of U.S. GAAP financial statements - foreign bank account reporting - Form TDF 90-22.1, Form 5471
  
  
• Computing earnings and profits for CFCs and 10/50 companies - Schs. C, H and J, Form 5471
  
  
• Preparation of Schedule M, Form 5471 - reporting intercompany transactions

10:30 am Refreshment Break

10:45 am U.S. Tax Issues in Structuring Foreign Operations

• Selecting a foreign corporate or pass-through entity - when a foreign entity can elect to be taxed as a conduit - per se corporations
  
  
• Understanding the U.S. tax consequences of making a check-the-box (CTB) election on Form 8832 - Dover and Guardian Industries cases
  
  
• Interrelationship with foreign tax credit and Subpart F provisions
  
  
• Recapture of overall foreign losses and dual consolidated loss issues

12:15 pm LUNCHEON

1:30 pm Maximizing Foreign Tax Credit Benefits

• Claiming direct foreign tax credit benefits - maintaining pools of foreign taxes available for credit
  


• Applying the foreign tax credit limitation formula for passive or general basket income and taxes



• Computation of the Sec. 78 gross-up for deemed paid taxes - interrelationship with the subpart F FPHCI rules



• FTC recharacterization and resourcing rules - treatment of overall foreign and domestic losses and separate basket limitation recapture
  

3:00 pm Refreshment Break

3:15pm Understanding the Subpart F Provisions

• How Subpart F accelerates the U.S. tax on earnings of CFCs - recent Jobs Act changes involving Subpart F and foreign PHCs
  
  
• Affirmative use of Subpart F income and investments in U.S. property - Jobs Act changes to Sec. 956 inclusions
  
  
• Application of the look-through rules and interrelationship with the foreign tax credit rules
  
  
• Planning for distributions of previously-taxed income (PTI) and other CFC earnings

4:45 pm Meeting Adjourns for the Day

Day Two

7:30 am Continental Breakfast

8:00 am Corporate International Tax Compliance

• 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 8621
   
• Maintaining worksheets for new Form 8858 for CTB entities
   
• Preparation of Form 8886 and Schedule M-3 for reporting significant book-tax differences

9:15 am Expense Apportionment

• How expense apportionment affects foreign tax credit and export tax benefits
  
  
• Understanding key definitions for class of income, statutory and residual groupings and gross income apportionment
  
  
• Application of expense apportionment to interest and research expense - treatment of stewardship, state tax and charitable deductions
  
  
• Adopting a plan of apportionment for sales, general and administrative expense

10:30 am Refreshment Break

10:45 am Documenting Related Party Transactions

• Effectively conducting a Transfer Pricing Study to mitigate adjustments in today's economic environment
   
• Proper use of economists in the preparation of a study
   
• Satisfying the year-end Sec. 6038A documentation rules for foreign-controlled U.S. companies – preparing Form 5472
   
• Avoiding IRS penalty assessments under Sec. 6662(e)
   
• Role of documentation in the audit process and FIN 48 implications

12:15 pm LUNCHEON

1:30 pm Computing the Gain from the Sale of CFC Shares under Sec. 1248

• How the U.S. taxes gain from the sale of shares in a CFC - interrelationship with the reorganization rules under Sec. 367(b)
  
  
• Determining gain (loss) on the liquidation of a CFC under Secs. 331 and 332
  
  
• U.S. tax consequences of making a Sec. 338 election on the sale of a CFC
  
  
• Comparison of the Sec. 1248 tax consequences of a sale of subsidiaries v. pre-sale repatriation of profits

2:30 pm Refreshment Break

2:45 pm Transfers of Stock and Assets to 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 rules for transfers of intangibles under Sec. 367(d)
  
  
• Organizing a foreign corporation or holding company - completing a Gain Recognition Agreement (Form 8838)
  
  
• Special issues involving non-taxable mergers and reorganizations under Sec. 367(b)

4:30 pm Meeting Ends

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Pricing

Regular Conference Price: $.00
Early Registration Price: $ .00*
*Early price valid for registrations received and paid up to one month prior to conference date

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March 26 & 27, 2012, Dallas April 2 & 3, 2012, Chicago May 7 & 8, 2012, Salt Lake City July 9 & 10, 2012, St. Louis

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