Events
Duane Morris Partner Hope Krebs to Speak at the Council for International Tax Education's Annual Conference Series: U.S. International Tax Reporting & Compliance
April 19, 2010 | Philadelphia
| Radisson Plaza-Warwick Hotel
Duane Morris partner Hope P. Krebs will be speaking at the Council for International Tax Education (CITE) Annual Conference Series on U.S. International Tax Reporting & Compliance, to be held on March 22-23, 2010, in Dallas, Texas; and on April 19-20, 2010, in Philadelphia, Pennsylvania. Ms. Krebs will discuss "U.S. Tax Issues in Structuring Foreign Operations" at the Philadelphia event. She will address the following topics:
- Special issues in structuring foreign operations for individual S corporation or LLC shareholders in a foreign entity
- Selecting a foreign corporate or pass-through entity—when a foreign entity can elect to be taxed as a conduit—per se corporations
- Understanding the U.S. tax consequences of making a check-the-box (CTB) election on Form 8832
- Interrelationship with foreign tax credit and Subpart F provisions
- Recapture of overall foreign and domestic losses and dual consolidated loss issues
About the Conference
In today's global business environment, U.S. and foreign-based multinational companies are expanding overseas and increasing their cross-border business activities. The U.S. Internal Revenue Service (IRS) has implemented extensive tax reporting requirements for monitoring foreign activities of U.S. companies. As a result, tax departments at multinational companies must constantly review their global operations and filing responsibilities to stay in compliance with the U.S. tax laws. For 2010, CITE is pleased to announce its 12th Annual Conference Series on U.S. Tax Reporting & Compliance. This two-day entry level and update session is designed to familiarize attendees with the latest IRS reporting requirements and review the latest forms and best practices for IRS international tax compliance.
Benefits of Attending
- Find out how companies obtain foreign tax data from affiliates overseas for preparing Forms 5471
- Discover how to report the results of check-the-box and other foreign disregarded entities on new Form 8858
- Ascertain how to satisfy the tax reporting requirements under Secs. 367 and 1248 for foreign mergers and reorganizations
- Learn how to compute the amount of tainted Subpart F earnings and file an election to exclude Subpart F amounts
- Review the preparation of Form 1118 and how to prepare worksheets for computing earnings and profits (E&P) and the amount of indirect credit (Sec. 78) gross-up
- Understand how the expense apportionment rules under Reg. Sec. 1.861-8 affect foreign tax credit benefits
- Find out recent trends in transfer pricing planning and managing cross-border audits in multiple tax jurisdictions
- All paid attendees receive a copy of the BNA Portfolio (#947) - Reporting Requirements under the Code for International Transactions
Who Should Attend
This basic-level and update session is designed for tax practitioners new to the international tax area or looking to update their knowledge of the latest U.S. international tax reporting and compliance requirements. Attendees include corporate tax managers, tax analysts, tax supervisors and controllers, as well as, tax accountants, attorneys and financial executives responsible for overseeing U.S. international tax compliance for their clients.
For more information or to register to attend the conference, please visit the CITE website.
