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Course/Product Description
Title:

Introduction to International Tax - 1 Day Workshop

Metropolitan Area: San Francisco
Event Venue: TBD
Address: San Francisco, CA
Contact Phone: 770-410-9941
Starting Date / Time: 8/2/2010  -  8:00 AM - 5:00 PM
Duration: 1 day
Description:

Introduction to International Tax - 1 Day Workshop
This one-day seminar gives you a basic understanding of how U.S. practictioners as multinational companies can reduce corporate taxes.

Our expert faculty analyzes and explains the key international tax topics that are currently being exaimined by the IRS, then allows you to ask important questions and receive one-on-one training.

There is no pre-requisite or advance preparation for this seminar.

Agenda

8:00 am Registration & Continental Breakfast

8:45 am Overview of U.S. International Taxation, Source of Income and Expense Apportionment
  • Residence For Taxation
  • Income From Single & Mixed Source
  • Establishing Foreign Title Passage-The Use of Incoterms
  • Tax Planning to Create or Increase Foreign Source Income
  • The Basic Rules of Allocation and Apportionment
  • The Apportionment of R&E Expenses
  • Asset Apportionment of Interest Expense
  • The Apportionment of SG&A Expenses
  • Apportionment of Other Expenses
  • Tax Planning in Expense Apportionment
10:15 am Refreshment Break

10:30 am Tax Reporting Requirements of Foreign Operations
  • Form 5471 - Filing Requirements, Obtaining Data, Computing E&P, Reporting Supbart F Income and Other Transactions
  • Form 8858 – Filing Requirements for Foreign Disregarded Entities
  • Form 8865 – Controlled Foreign Partnerships
  • Form 1118 – U.S. Foreign Tax Credits
  • Form TDF 90-22.1 – Foreign Bank Account Reporting
11:30 pm - The Foreign Tax Credit
  • Determining A Creditable Tax
  • The Foreign Tax Credit Limitation Formula
  • The Direct Credit
  • The Deemed Paid Credit
  • Foreign Tax Credit Baskets
  • Redeterminations Under Section 905(c)
12:30 pm Luncheon

1:30 pm CFCs, PFICs & Subpart F Income
  • The Determination of a Controlled Foreign Corporation
  • Classification-The Income Test and The Asset Test
  • Exceptions to PFIC Status
  • Consequences of PFIC Status
  • Tax Planning for PFICs
  • Understanding Foreign Base Company Income
  • Exceptions and Limitations to Subpart F
  • Section 956 Investments in US Property
  • Treatment of Previously Taxed Income
2:30 pm Transfer Pricing
  • Overview of Section 482-The Arm’s Length Standard
  • Determining The Best Method for Sales Of Products
  • What Companies Must Utilize CUP, Resale Price, or Cost Plus
  • When CPM Applies-Factors Determining Comparability
  • Preparing/Reviewing a Transfer Pricing Study
  • Multi-Jurisdictional Use of a Transfer Pricing Study
3:30 pm Refreshment Break

3:45 pm Earnings & Profits
  • The Importance of Earnings and Profits in International Tax
  • The Steps in Preparing an Earnings & Profits Study
  • Preparing a Computation of Earnings & Profits-Pre-1987
  • Preparing a Computation of Earnings & Profits-Post-1986
  • Common Earnings and Profits Adjustments
  • Practical Issues Involved in Calculating Earnings and Profits
4:45 pm Question & Answer Session

5:00pm Seminar Concludes


Who Should Attend

This course is for beginners to the international tax field but have a background in domestic corporate taxation such as tax managers, analyst, specialists, CPAs, tax attorneys and in-house counsel abd those wanting to refesh their knowledge. This seminar is transitional and non-transitional which is appropriate for both newly admitted attorneys and experienced attorneys.

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.

Houston: TBD

Cancellations/Substitutions

All cancellations must be received 5 business days prior to seminar date to receive a refund minus a $100 processing charge. You can send a substitute or you can also request a credit in full to attend another seminar. No refunds will 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.


To view available dates and locations for our Introduction to International Tax - 2 Day Workshop, click here.

Licenses / Designations / Educational Credits: CPE
All US States: 8

CLE
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
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