ARLINGTON, Va., Sept. 20 /PRNewswire-USNewswire/ -- Congress has approved a number of significant international tax changes that will impact multinational corporations, including modifications relating to the operation of the foreign tax credit. September 21st, three legislative counsels to the Joint Committee on Taxation will join tax experts from Grant Thornton and DLA Piper to answer practitioner questions relating to these provisions in The Latest U.S. International Tax Legislation: What You Need to Know About H.R. 1586, a 90-minute webinar from BNA Tax & Accounting.
This BNA webcast will discuss:
- Rules to Prevent Splitting Foreign Tax Credits from the Income to which they Relate
- Denial of Certain Foreign Tax Credits for Covered Asset Acquisitions (including Section 338(g) transactions)
- Limitation on the Amount of Foreign Taxes Deemed Paid with Respect to Section 956 (the "956 Hopscotch Rule")
- Special Rule with respect to Certain Redemptions by Foreign Subsidiaries (targeting certain section 304 transactions)
- Modification of Affiliation Rules for Purposes of Rules for Allocating Interest Expense
- Termination of Special Rules for Interest and Dividends Received from Persons Meeting the 80% Foreign Business Requirements
- Limitation on the Extension of the Statute of Limitations for Failure to Notify the Secretary of Certain Foreign Transfers
By attending this webinar, practitioners:
- Will understand the foreign tax credit changes included in H.R. 1586, including the reasons for those changes;
- Will be familiar with the other changes included in H.R. 1586, including interest allocation, repeal of the 80/20 company rules, and the technical correction to the statute of limitations;
- Will understand the effective dates of these provisions, including grandfathering rules;
- Will be able to advise your clients on the implementation of these amendments.
Cynthia B. Lafuente serves as Legislation Counsel, Joint Committee on Taxation, United States Congress. In her role, Cyndi serves as a nonpartisan tax resource to Congress on international tax matters. In this role, Cyndi provides counsel to the tax writing staffs of the House Ways & Means and Senate Finance Committees, the Senate Foreign Relations Committee, and individual Members of Congress on legislative proposals, international tax developments and treaties. Prior to joining JCT, Cyndi was the General Tax Counsel and Divisional Vice President, Tax Planning, for Abbott Laboratories, a $30 billion manufacturer of pharmaceutical, medical, and nutritional products based in the Chicago area.
Kevin Levingston is a member of the legislative and policy staff of the Joint Committee on Taxation ("JCT"). The JCT is a nonpartisan committee of the United States Congress that operates to assist members of the majority and minority parties in both houses of Congress on tax legislation. Due to its non-partisan stature, it interacts with members of Congress, tax-writing committees and their staffs and ensures consistency on tax bills moving through the floor of each chamber, and to a House-Senate conference committee. Kevin focuses on international tax legislative matters.
Prior to joining the JCT in March 2009, Kevin was a Director with PricewaterhouseCoopers (PwC) in its Atlanta tax practice. While at PwC, Kevin assisted US and foreign multinational corporations with domestic and non-US tax planning, tax compliance, and income tax accounting related issues.
Kristeen R. Witt is Legislation Counsel at the Joint Committee on Taxation. Ms. Witt joined the Joint Committee in 2008. Ms. Witt previously worked as the Tax Director for Zimmer Holdings, Inc.; as the Director of Domestic Tax Planning at Yum! Brands, Inc. (previously Tricon Global Restaurants, Inc.), and as a Tax Planning Manager at Coopers & Lybrand.
Joe Calianno is partner and the International Technical Tax Practice Leader in the National Tax Office of Grant Thornton LLP. He practices in all areas of international taxation and helps assist the offices around the firm and the firm's clients with complex international issues. Prior to joining Grant Thornton LLP, Joe was a Special Counsel to the Deputy Associate Chief Counsel (International) in the office of Chief Counsel, Internal Revenue Service. As a Special Counsel, he was the technical advisor to the Associate and Deputy Associate Chief Counsel (International) and was involved in reviewing international regulations, revenue rulings, Notices, TAMs, PLRs and providing technical advice to the field.
Alan Winston Granwell (moderator) is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell's practice encompasses representing multinational corporations and high-net worth individuals on cross-border transactions and controversies. He conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings, advising taxpayers on voluntary disclosures, assisting clients in obtaining regulatory changes and tax rulings and advising clients on tax legislation matters). From 1981 through 1984, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs at the US Department of the Treasury.
The Latest U.S. International Tax Legislation: What You Need to Know About H.R. 1586 takes place September 21, 2010, from 12:30 – 2:00 pm, ET). Register for this webinar and obtain further information about CLE and CPE credits, go to http://www.bnatax.com/investment-fee-disclosure-webinar/?open&cmpid=tmtxpr2010 or call 1-800-372-1033, menu Option 6, then Option 1. The fee is $249 for BNA subscribers, $299 for nonsubscribers.
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About BNA Tax & Accounting Webinars
BNA Tax & Accounting is the foremost source of tax and accounting research, news, practice tools, and guidance for tax attorneys, CPAs, corporate tax managers, estate planners, and financial accountants. Designed for today's busy practitioners, our webinars offer the same expertise and relevance that are the hallmark of all BNA Tax & Accounting resources. In just 60-90 minutes, practitioners gain in-depth knowledge on a current tax or accounting topic from experts in that area — and benefit from practical applications that can be put to work immediately. Conference attendees have the opportunity to ask the speakers questions, and may be eligible to earn CLE or CPE credits — all from the convenience of their own office or conference room.
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