Course/Product Description Title: U.S. International Tax Planning Duration: 3 days Description: In 2009, many Tax Departments face adverse business results at U.S. and foreign operations and are looking for opportunities to repatriate cash and cut costs, including taxes, in doing business overseas. The IRS has stepped up regulation of international businesses and issued extensive revisions to the Sec. 482 Cost-Sharing and Subpart F (Branch Rule) regulations. In addition, the IRS has made international tax audits and preparation of Form 5471 a Tier 1 issue. For companies with current operating losses, discover if your company is subject to an overall foreign or domestic loss and potential foreign tax credit or Subpart F recapture in 2010 or later years. Find out how the latest international tax reform proposals from the Obama Administration will affect your business or clients in 2009. In addition, learn how restructuring foreign operations may be more feasible in today’s economic environment. Join CITE in 2009 for its updated and improved course on International Tax Planning. Upgrade your job skills and network with our attendees and STAR (Speakers with Top Attendee Ratings) faculty involved in tax planning for U.S. corporations and their shareholders. For 2009, a new topic has been added on the Use of Income Tax Treaties in Cross-Border Tax Planning. Find out how recent U.S. treaties eliminate or lower withholding taxes on intercompany dividends and interest and now contain arbitration provisions for resolving treaty tax disputes. Benefits of Attending NEW TOPIC! – Discuss the use of income tax treaties in cross-border tax planning Learn how the recent tax law changes affect international tax planning at your company Discover U.S. tax recapture consequences of a dual consolidated or branch loss and an overall foreign or domestic loss Find out how the latest FIN 48 provisions affect Tax Department accounting for cross-border activities Understand the latest IRS rules under Sec. 987 for taxing remittances from foreign disregarded entities Learn how to compute foreign tax credit benefits for separate basket income under the new Jobs Act transition rules Find out the latest interest and R&D expense apportionment rules for foreign tax credit and domestic production activities Understand the latest U.S. tax changes to the Subpart F provisions Learn about Subpart F planning for the use of contract manufacturing or toll packing operations under the latest branch manufacturing rules 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 Schedule Day 1 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 10:15 am Break for Refreshments 10:30am Structuring Foreign Disregarded or Check-the-Box (CTB) Entities 12:15 pm LUNCHEON 1:30 pm Computing Direct and Indirect Foreign Tax Credit Benefits 3:15 pm Break for Refreshments 3:30 pm Expense Apportionment Update 5:00 pm Meeting Adjourns for the Day Day 2 8:00 am Continental Breakfast 8:45 am How the Subpart F Anti-Tax Deferral Rules Operate 10:30 am Refreshment Break 10:45 am Complying with the IRS Rules for Intercompany Transactions 12:15 pm LUNCHEON 1:15 pm Use of Income Tax Treaties in Cross-Border Tax Planning 3:00 pm Refreshments Break 3:15 pm Interrelationship with the Tax Accounting Rules (FAS #109) 5:00 pm Meeting Adjourns for the Day Day 3 8:00 am Continental Breakfast 8:15 am Corporate International Tax Compliance - 2009 9:30 am Taxable Transfers of CFC Stock by U.S. Shareholders 11:00 am Break for Refreshments 11:15 am Tax-Free International Mergers and Acquisitions under Sec. 367 12:15 pm Meeting Ends Accommodations A limited block of rooms at a reduced rate has been set aside for attendees of our conferences. Please contact the appropriate hotel and mention that you are attending the conference listed under the Council for International Tax Education (CITE) in order to receive the discounted rate. Sleeping rooms are available on a very limited basis. We cannot guarantee rates or availability. Your sleeping room is not included in your registration fee. 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. Credits will not be issued for “no shows”. No credit card or cash refunds will be issued at any time. Licenses / Designations / Educational Credits: CPE / CLE All US States: 20 About The Provider: The Council for International Tax Education (CITE, Inc), a non-profit organization, was formed to educate U.S. and foreign multinationals and companies engaged in international business on the tax, legal and accounting aspects of doing business overseas. Seminar speakers are experts in internal taxation and finance fields and the participants include a broad range of corporate multinational companies. CITE was formerly part of the FSC/DISC Tax Association, Inc. (FDTA) which was formed in 1984. CITE was an outgrowth of the need expressed by our association members to obtain educational seminars and written materials on other areas of international taxation. CITE provides tax publications, newsletters and educational seminars to fulfill its mission. Substitutions/Cancellations Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $250 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. Price: $1,595.00 More Info: Contact Us For More Information

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