Course/Product Description Title: International Tax Update Metropolitan Area: San Francisco Event Venue: TBD Address: San Francisco, CA Contact Phone: 770-410-9941 Starting Date / Time: 8/3/2010  -  8:00 AM - 5:00 PM Duration: 1 day Description: This seminar provides updates on the latest developments in international tax. Our faculty will also answer your questions and concerns on recent developments in international taxation. You also get to network and learn from our international tax experts as they provide you with a comprehensive overview of how to reduce U.S. taxes on corporations with operations aboard. Agenda 8:30 am Registration & Breakfast 9:00 am Introduction & Overview 9:15 am New Contract Manufacturing Regulations Rejection of the ‘Its” Argument The New Definition of Manufacturing Branch Rule Changes Multiple Branch Rules Examples 10:30 Refreshment Break 10:45 am The New Service Rules Under Code Section 482 General Observations on Headquarter Company Costs Specified Covered Services and the Business Judgment Test When a Related Party Must Charge for Services The Benefits of Intercompany Service Agreements Allocation of Costs From Shared or Centralized Services 11:45 pm The Obama International Tax Proposals Reform of the Foreign Tax Credit Pooling for the “deemed-paid” credit Preventing the split of foreign income and foreign taxes Tax Changes To Transfers Of Intangibles New limits on the transfers of intangibles offshore Current taxation of intangibles offshore Deferral of interest expense related to deferred income Other proposed changes Disallowance of excess reinsurance premiums Repeal Of 80/20 rules Modification of dual capacity taxpayer rules 12:45 pm Luncheon 1:30 pm Tax Controversies Federal and State Tax Audit process and Administrative Appeal Resolving Disputes Understanding of Tax Matters Arising in Controversies FIN 48 Analyses 2:30 pm International M&A Developments Proposed Regulations Under Section 367(a)(5) for Outbound Transfers Modification of the Basis Rules for Section 956 Outbound 304 Transactions and New 304 Anti-Abuse Rule Proposed Regulations Under Section 336(e) 3:30 pm Refreshment Break 3:45 pm Treaty Developments/Current International Audit Issues New US Model Treaty Changes The Changing Definition of a Permanent Establishment New US/Canada Protocol US/UK Competent Authority Agreement Hybrid Instruments Cost Sharing 4:45 pm Questions & Answers 5:00 pm Seminar Concludes Who Should Attend This course is designed for intermediate practitioners in international taxation. This includes corporate finance and tax professionals, attorneys, certified public accountants, tax managers, tax directors, controllers, CFOs and VP of taxes. This seminar is transitional and non-transitional which is appropriate for both newly admitted attorneys and experienced attorneys. Prerequisite: You must have attended a basic level or introductory course on international tax. Continuing Education Credits Up to 8 CPE/CLE Credits CPE Credits: Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. www.nasba.org CLE Credits: Continuing Legal Education Credits will be sought by those who request it at the seminar. Each state will have final approval on the exact number of credits granted. Transitional and/or non-transitional continuing legal education is available depending on the level of seminar. Accreditation is pending until approved by each CLE board. CLE is an important aspect of our seminars and we want to make sure you receive the appropriate accreditation. Accommodations Recommended hotels are listed below. Please contact the hotel and mention that you are attending under Networking Seminars in order to receive any discounted rate. Your sleeping room is not included in your registration fee. Boston: The Langham, Boston 250 Franklin St Boston, MA 02110 617-451-1900 The Hilton Financial District 89 Broad Street Boston, MA 02110 617-556-0006 San Francisco: Hotel Monaco 501 Geary Street at Taylor San Francisco, CA 94102 415-292-0100 Philadelphia: TBD Miami: TBD Houston: TBD Cancellations/Substitutions All cancellations must be received 5 business days prior to seminar date to receive a refund less a $100 processing charge. You can send a substitute or you can also request a credit in full to attend another seminar. No refunds can be processed within 5 business days of the seminar. You would, at that point, receive a credit to attend another seminar. If you fail to attend or inform us of your cancellation, you will lose your opportunity to request a refund or credit for the seminar. Licenses / Designations / Educational Credits: CLE/CPE All US States: 8 About The Provider: Networking Seminars organizes educational seminars and unique networking events on cutting edge information for the tax, legal, finance and accounting industries. We bring together an international community of professionals and industry experts to learn the latest news and informaton, exchange ideas, share experiences and cultivate new business relationships. Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. We also offer CLE course credits and file with each state by those requesting credit at the seminar. Price: $595.00 More Info: Contact Us For More Information Click Here For More Cities And Dates To order this product by check/invoice or credit card, enter desired quantity here >>> Qty:

Keywords For This Course:
international tax, international taxation, CPE seminars CPE courses, CLE seminars, intermeidate tax seminar, taxation seminars, tax seminars, CPA training, New contract manufacturing Regulations, recent Changes to the Foreign Tax Credit, The New Service Rules under Section 482, International M&A Developments, Treaty Developments/Current International Audit Issues and International Tax Accounting and Transparency.