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Outbound Transactions and U.S. Federal Tax

Webinar: ID# 1011773
Recorded CD
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About This Course:
Tax specialists must stay abreast of complex and evolving IRS regulations affecting outbound transactions (investments by U.S. companies, or their business relationships, in foreign countries), in order to handle compliance challenges arising with IRS forms such as 5471, 926, 8865 and 8895, among others.

To properly navigate forms preparation on outbound transactions, tax professionals often will need to turn to IRS rules such as Sect. 351 on controlled foreign corporations, Sect. 367(a) and (b) on CFC restructurings, and Sect. 7874 on anti-inversion — as well as tax treaties and check-the-box rules.

A review of the key governing concepts from federal regulation, and a discussion of the more problematic aspects of related IRS forms, will prepare you to handle tax compliance on outbound transactions confidently and completely, as U.S. companies' international ties proliferate.

Listen as our panel of tax advisors reviews the most important principles of U.S. taxation of outbound transactions in a practical context to meet the toughest challenges in preparing related IRS forms.

Outline

I. Overview of key concepts

  • Worldwide income and foreign tax credits
  • Entity structures
  • CFCs and Subpart F
  • Re-organizations and asset transfers
  • Anti-inversion rules
  • Tax treaties

II. Issues to anticipate U.S. forms and schedules

  • Form 5471
  • Form 926
  • Form 8865
  • Form 8895
  • Others

Benefits
The panel will address these and other topics that have a material impact on outbound transactions forms compliance:

  • Tax implications of choice of entity and check-the-box regulations for U.S.-owned foreign companies.
  • The "control" standard for foreign entity ownership.
  • Controlled foreign corporation restructuring and the tax impact of asset transfers outside the U.S.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Upon completing this seminar, you will have a better understanding of key concepts affecting U.S. taxation of outbound transactions and be better equipped to prepare required federal forms.

Faculty

Christopher Karachale, Senior Counsel, HansonBridgett, San Francisco

He works with business and individual clients on a broad range of tax planning and controversy engagements, including international tax compliance along with associated voluntary disclosures and planning.

Melinda Fellner Bramwit, Member, Norris McLaughlin &Marcus, Bridgewater, N.J.

Her practice emphasizes federal, state and international tax planning and transactions, particularly in regard to corporate acquisitions. She routinely represents clients in federal and state tax controversies and on IRS offshore voluntary compliance participation.

Vinay Navani, Shareholder, Wilkin &Gutterplan, East Brunswick, N.J.

He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international business, income tax planning and compliance matters. He previously worked on tax research services for the AICPA.


Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. CPE Credit is available only for the LIVE webcast. Recorded versions do not qualify for credit.

Strafford 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.

Processing

To obtain CPE credit, attendees must participate in the live event, return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Credit Confirmation

Strafford will mail a certificate of credit within approximately 2 weeks of receiving an attendee's completed Official Record of Attendance—provided all required conditions have been satisfied.


Delivery

Handout materials and the phone number for live presentations are made available to you 1 day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CD's will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.


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Outbound Transactions and U.S. Federal Tax
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