ARLINGTON, Va., April 11, 2012 /PRNewswire-USNewswire/ -- Bloomberg BNA | CITE will host a live conference, U.S. International Tax Planning, May 21-23 in Houston, Texas, that will provide the latest U.S. tax developments and tax strategies for U.S. companies with operations overseas.
Recent legislation passed in Congress requires tax practitioners to understand and implement a number of new foreign tax reporting and compliance procedures to determine their tax liability for 2012. In addition, the IRS has stepped up its efforts and penalties in auditing foreign activities and operations of U.S. multinationals.
"In addition to extending tax rates, the new provisions contain changes in the international tax provisions that may increase the U.S. tax cost of remitting foreign earnings, including cash or Subpart F dividends," notes Diane Pastore, Executive Director at Bloomberg BNA | CITE.
This conference will provide guidance for understanding the new rules for interest apportionment, the latest regulations involving Subpart F FPHC income, and the new intercompany service regulations: charging for headquarter services and imbedded intangibles.
The effect of new FTC limitations on dividends under Subpart F and Sec. 956 and the use of the new statutory merger or consolidation rules for an acquisition of foreign tangible and intangible assets will also be addressed.
Various sessions will examine reporting the results of foreign operations and activities, understanding the rules for computing foreign exchange gain (loss), and computing direct and indirect foreign tax credit benefits. In addition, the Subpart F anti-tax deferral rules, the interrelationship with the tax accounting rules (ASC 740), taxable transfers of CFC stock by U.S. shareholders, and tax-free international mergers and acquisitions under Sec. 367 will be covered.
By attending the two-and-one-half day conference, attendees will:
Find out how the latest legislative changes affect their company's tax planning and compliance strategies in 2012
Determine the latest tax benefits and non-benefits of using a hybrid entity overseas
Learn the latest IRS regulations affecting the treatment of foreign exchange gain (loss) recognized by non-U.S. branches and disregarded entities
Discover how the foreign tax credit changes limit FTC benefits and affect FTC baskets and gross-up calculations
Understand the latest expense apportionment rules for interest and R&D and how they can reduce foreign tax credit benefits
Learn the latest Subpart F rules for foreign base company income and investments in U.S. property and strategies for remitting dividends
Ascertain how the latest U.S. tax legislation limits FTC benefits in cross-border mergers and in Sec. 338 acquisitions
Determine the 2012 U.S. tax consequences under Sec. 1248 of CFC sales by U.S. companies and individuals
Find out the 2012 U.S. tax filing and compliance requirements for foreign entities and transactions
Analyze the impact of the U.S. transfer pricing rules on foreign profits of multinationals and evaluate IRS audit exposure in reporting uncertain tax positions
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