This webinar will provide an essential update on the international tax landscape post-election. Our panel of experienced international tax consultants will analyze the potential international tax policy and regulatory environment under the elected administration and composition of Congress post-elec... Read More

This webinar will review the potential impact of the Supreme Court's decision in Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244, 2273 (2024) on global taxpayers. Our panel of international tax advisers will examine the decision and the history of courts' deference to agency interpretations and su... Read More

This webinar will review the fundamentals of the dual consolidated loss (DCL) rules under IRC Section 1503(d) to global entity structures and the effect of the new proposed regulations on existing structures for international companies and their advisers. Our panel of international mergers and acqui... Read More

This course will provide tax advisers and compliance professionals with a practical guide to the basic calculations and reporting requirements for U.S. taxpayers and exiting green card holders. The panel will discuss the rules of Section 877A, determining whether a taxpayer is a covered expatriate,... Read More

This course will explain foreign branches' tax considerations, including what constitutes a foreign branch and its U.S. reporting obligations, calculating foreign branch income and the related foreign tax credit, and the recent 267A anti-hybrid regulations. Read More

This webinar will review vehicles individuals can use to support overseas charities and receive a U.S. charitable income tax deduction, as well as some considerations related to donations by U.S. taxpayers who live outside the U.S. and the formation and operation of private foundations. Read More

This webinar will discuss tax consequences of cross-border transactions. Our knowledgeable panel of foreign planning professionals will discuss outbound transfers, foreign acquisitions and section 338(g) elections, and section 7874 inversion transaction. Read More

This course will furnish tax advisers with a thorough and practical guide to reporting investments in a passive foreign investment company (PFIC) on IRS Form 8621. The panel will identify those investments that require PFIC reporting, outline the various elections available to taxpayers holding inte... Read More

This course will discuss the complications surrounding the determination of foreign earnings and profits (E&P) for controlled foreign corporations (CFCs). Our panel of foreign tax experts will discuss the complexities of the related calculations, including categorizing income, handling retroactive a... Read More

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and nonresidential rentals, and properly reporting rental income and expenses with a... Read More

This course will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recently released regulations and considering the addition of the new Schedules K-2 and K3 for pass-through entities. The panel will outline which foreign taxes are eligible for... Read More

This course will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC (interest charge-domestic international sales corporation) formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including cal... Read More

This course will provide tax advisers with a practical guide to the global intangible low-taxed income (GILTI) provisions. The panel will detail the tax calculations and reporting requirements for taxpayers with GILTI inclusions and describe planning opportunities to minimize the tax impact on indiv... Read More

This webinar will look at opportunities to maximize the foreign tax credit (or deduction) for individual taxpayers. Our panel of global tax specialists will walk international tax advisers through common foreign tax credit scenarios and explain the steps to take to maximize this lucrative credit. Read More

This webinar will examine the tax implications of purchasing real estate abroad. Our panel of foreign tax experts will explain the U.S. tax benefits of holding property abroad, holding structure considerations, and the particulars of buying real estate in certain countries, including Spain, the Unit... Read More

This course will provide CFC shareholders and tax professionals with a comprehensive understanding of the final global intangible low-taxed income (GILTI) High Foreign Tax Exclusion Regulations (T.D. 9902). Our panel of international tax experts will explain how the final regulations change the orig... Read More

This course will guide tax advisers in making a Section 962 election for an individual, trust, or estate to be taxed at corporate rates on foreign-sourced income under Section 951(a) and global intangible low-taxed income (GILTI) treated in the "same manner" as Subpart F inclusions. The panel will s... Read More

This course will provide tax advisers and return preparers with a practical guide to completing Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships. The panel will discuss how to correctly identify the taxpayer category, determine the allocable share of foreign income, com... Read More

This webinar will review the economic substance doctrine from the perspective of the U.S., EU, and offshore jurisdictions. Our panel of global tax attorneys will explain how to comply with the U.S. economic substance rules, European directives, and similar requirements of other offshore locations, i... Read More

This course will guide tax advisers to the U.S. reporting requirements for ownership of foreign disregarded entities (FDEs) on IRS Form 8858. The panel will offer section-by-section detail on completing Form 8858, discuss the interrelation between Form 8858 and other required international informati... Read More

This webinar will discuss the impact of recent changes to the deductibility of research and experimental expenditures (R&E) on multinational taxpayers. Our panel of international tax advisers will clarify what costs constitute R&E expenses, explain how these costs should be treated, and provide exam... Read More

This course will provide tax advisers with a practical overview of the significant to Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail in plain language the specific areas of Subpart F, including the downward attribution rules, recent final and proposed regula... Read More

This webinar will address the tax consequences of employees working overseas remotely. The panelist will outline work status and VISA considerations, address data security concerns, and recommend employer policies that all businesses should have in place. The panelist will point out proactive consid... Read More

This course will provide tax advisers and professionals with a sound foundation for identifying foreign tax and asset information requirements for outbound transactions. The webinar will identify reporting requirements, explain outbound filing duties, and detail the intersection between information... Read More

This course will provide tax advisers with practical guidance on the advantages and pitfalls of utilizing the check-the-box entity selection for U.S. individuals with offshore business activities. The panel will discuss the various tax effects of specific elections, outline the tax timing and treatm... Read More

This webinar will analyze the most recent and relevant court cases affecting international taxpayers. Our panel of foreign tax veterans will detail the status of recent and notable cases and offer insights for handling common international tax and compliance problems. Read More

This course will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recently released regulations and considering the addition of the new Schedules K-2 and K3 for pass-through entities. The panel will outline which foreign taxes are eligible for... Read More

This course will guide tax advisers to the U.S. reporting requirements for ownership of foreign disregarded entities (FDEs) on IRS Form 8858. The panel will offer section-by-section detail on completing Form 8858, discuss the interrelation between Form 8858 and other required international informati... Read More

This course will guide tax advisers to the U.S. reporting requirements for ownership of foreign disregarded entities (FDEs) on IRS Form 8858. The panel will offer section-by-section detail on completing Form 8858, discuss the interrelation between Form 8858 and other required international informati... Read More

This course will point out specific actions that accelerate the deferred payment of tax on repatriated earnings under IRC Section 965. Our veteran panel of foreign tax experts will discuss which actions are curable, how to cure these, and identify ways to avoid activities triggering the acceleration... Read More

This course will cover repatriation issues for multinational taxpayers. Our panel of foreign tax experts will examine distributions of E&P from PTEP, non-PTEP, and the return of basis and explain the tax considerations and benefits available for each distribution type. Read More

This course will discuss ways to mitigate the tax burden for foreign athletes and entertainers. Our international taxation experts will discuss residency requirements along with structuring opportunities, tax treaty benefits, and withholding considerations for U.S. resident and nonresident performer... Read More

This course will cover the disallowance of deductions for certain hybrid transactions with related parties under Section 267A, including an analysis of the April 2020 finalized and proposed regulations. Read More

This course will provide a comprehensive review of how income is sourced to the U.S. and other countries. Our authoritative panel will provide insights to help mitigate multi-country taxation and avoid improper classifications of income. They will explain the benefits available in particular income... Read More

This course will weigh the pros and cons of holding structure choices for foreign investments made by U.S. taxpayers. Our panel will explore the tax impact of entity choice as well as relief available for advisers working with taxpayers with global income. Read More

This course will provide tax advisers with a guide to the framework of reporting foreign income and its accompanying tax obligations. The panel will detail the tax treatment of various classes of income, describe the remaining framework of deferral opportunities, credits for foreign taxes paid, tax... Read More

This course will provide tax advisers with a practical overview of the significant changes the 2017 tax reform law made to Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail in plain language the specific areas where the law expanded Subpart F, including for exa... Read More

This course will provide tax advisers with practical guidance on the advantages and pitfalls of utilizing the "check-the-box" entity selection for U.S. individuals with offshore business activities. The panel will discuss the various tax effects of specific elections, outline the tax timing and tax... Read More

This course will provide tax advisers to individuals with a practical guide to the tax implications of Section 338(g) election on the purchase of controlled foreign corporation (CFC) stock. The panel will discuss the mechanics of taking a basis adjustment under IRC 338(g) and describe how the 2017 t... Read More

This course will provide tax advisers with a critical first look at new IRS proposed guidance on calculating foreign tax credit (FTC) limitations under Section 904. The panel will outline which additional "buckets" for foreign income grouping the new regulations create, discuss new rules regarding t... Read More

This course will provide tax advisers to individuals owning controlling shares in foreign businesses with a practical guide to the tax and operational impacts of selecting the entity form for those foreign entities. The panelist will discuss the full range of short-term and long-term tax issues that... Read More

This course will provide tax advisers with a detailed analysis of Section 1291 reporting including how to perform the onerous calculations and determine available elections to ease the burden. The panel will go beyond the basics to provide examples of PFIC disclosures on fund statements and illustra... Read More

This course will provide tax advisers with a practical guide to the deemed repatriation provisions of the new tax reform bill, with a focus on the specific compliance aspects of the requirement to recognize all post-1986 deferred foreign source income. The panel will go beyond the basics of what the... Read More

This course will provide tax advisers and compliance professionals with a critical first look at the practical impact of the new tax overhaul bill on U.S taxpayers with foreign income and tax reporting obligations. The panel will examine the major changes the new law imposes on calculating and repor... Read More

This course will provide tax advisers with a deep exploration of the reporting of income from and ownership of a foreign personal holding company. The panel will identify the tests for determining whether an investment qualifies as a FPHC, outline what qualifies as foreign personal holding company i... Read More