This CLE/CPE course will provide tax counsel and ERISA attorneys a detailed analysis of the tax rules governing foreign pension accounts, with a specific focus on avoiding penalties for noncompliance. The webinar will go beyond the basics to offer useful practice pointers on the application of IRC 4... Read More

This CLE/CPE course will provide tax attorneys and accountants with a detailed discussion of best practices for requesting relief from IRS penalties as a result of failing to timely file required international information forms such as Forms 5471, 5472, 3520, 3520-8858, 8865, 926, and the FBAR. The... Read More

This CLE/CPE course will provide tax professionals guidance on key U.S. tax planning strategies available to foreign nationals and pitfalls to avoid. The panel will discuss key considerations for resident and nonresident aliens for U.S. tax purposes, sourcing of income and challenges that disrupt ta... Read More

This CLE/CPE course will guide tax professionals on the challenges of the global intangible low-taxed income (GILTI) provisions under current tax law and the recent GILTI high-tax exception. The panel will discuss IRS final regulations and the high-tax exception, treatment of controlled foreign corp... Read More

This CLE/CPE webinar will provide tax counsel and advisers with a thorough and practical guide to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in India, as well as Indian citizens with U.S. tax reporting obligations. The panel will discuss U.S.... Read More

This course will guide tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually owned controlled foreign corporations (CFCs) under current tax law. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investme... Read More

This CLE/CPE webinar will provide tax guidance on Puerto Rico residency tax benefits and incentives for individuals and businesses and navigating applicable tax rules and IRS examination for Puerto Rico Act 60 grantees. The panel will discuss best practices to prepare for IRS audits for individuals... Read More

This CLE/CPE course will provide tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global intangible low-taxed income (GILTI). The panel will discuss how GILTI is calculated and key tax GILTI reporting issues involving IRS Forms 5471, 899... Read More

This CLE/CPE course will provide tax counsel and advisers guidance for calculating Subpart F and passive foreign investment company (PFIC) inclusions and final tax rules and regulations. The panel will discuss key provisions of the final rules, the impact on U.S. investors who own interests in forei... Read More

This CLE/CPE course will provide tax counsel and advisers with a practical guide to issues that arise in relation to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in the United Kingdom, as well as UK citizens with U.S. tax reporting obligations.... Read More

This CLE/CPE webinar will provide tax attorneys and advisers guidance on the compliance and reporting requirements of the Corporate Transparency Act of 2021 (CTA) which took effect Jan. 1, 2024. Our panel will also address issues relating to (1.) the obligations of professional advisers to inform fo... Read More

This CLE/CPE webinar will provide tax guidance on Puerto Rico residency tax benefits and incentives for individuals and businesses and navigating applicable tax rules and IRS examination for Puerto Rico Act 60 grantees. The panel will discuss best practices to prepare for IRS audits for individuals... Read More

This CLE/CPE course will provide tax professionals with an in-depth discussion of reporting Subpart F income challenges. The panel will discuss the proper methods of determining the Subpart F income earned by U.S. persons who qualify as U.S. shareholders of controlled foreign corporations (CFCs) and... Read More

This CLE/CPE course will provide tax counsel and compliance professionals guidance on the rules, reporting requirements, and available tax planning mechanisms for U.S. nonresident alien taxpayers. The panel will offer approaches for determining taxpayer classification, identifying and reporting inco... Read More

This CLE/CPE webinar will provide tax counsel and advisers guidance on recent developments in U.S. international taxation and related IRS guidance for foreign activities of individuals and companies. The panel will review complex international tax issues associated with cross-border activities and t... Read More

This CLE/CPE webinar will provide tax professionals with an in-depth analysis of the net investment income tax (NIIT) relief under current U.S. tax law and the interplay with income tax treaties. The panel will discuss the recent court ruling in Christensen v. United States and the IRS' appeal of su... Read More

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning mechanisms. The panel will discuss recent IRS guidance, key tax considerations i... Read More

This CLE/CPE webinar will provide tax counsel guidance on the U.S. tax treatment of foreign rental income and international real estate investments. The panel will discuss U.S. sourcing of income rules, exemptions, and reporting requirements. The panel will also provide insights into typical structu... Read More

This CLE/CPE webinar will provide tax professionals and advisers with an in-depth discussion of the IRS examination of taxpayers living abroad. The panel will focus on Section 965 transition tax, exit tax, and critical issues for non-filers; guide tax practitioners through the examination process; a... Read More

This CLE/CPE webinar will provide tax counsel with a comprehensive guide to tax planning challenges and opportunities for clients who have or are seeking a tax presence in both the US and Latin America. The panel will discuss recent US-Chile tax treaty provisions that govern tax and fiduciary rules,... Read More

This CLE/CPE webinar will provide tax counsel and advisers with a practical discussion of the tax implications, reporting requirements of cross-border activities, and issue-based examinations of foreign activities of individuals and companies. The panel will review complex international tax issues a... Read More

This CLE/CPE webinar will provide tax professionals guidance on the key provisions of the U.S.-Chile Tax Treaty, tax reporting requirements, and opportunities for U.S. taxpayers with earnings or assets in Chile, as well as Chilean citizens and businesses with U.S. tax reporting obligations. The pane... Read More

This CLE/CPE course will provide tax counsel with a thorough and practical guide to structuring alternatives and tax considerations for foreign investors in U.S. real estate. The panel will outline best practices for determining the purchasing entity and review tax planning opportunities in structur... Read More

This CLE/CPE webinar will provide tax attorneys and advisers guidance on the compliance and reporting requirements of the Corporate Transparency Act of 2021 (CTA), effective Jan. 1, 2024. Our panel also will address issues relating to (1) the obligations of professional advisers to inform former or... Read More

This CLE/CPE webinar will provide tax counsel and advisers with a comprehensive guide to pre-immigration tax and investment planning challenges and opportunities under current tax law. The panel will discuss strategies for minimizing the U.S. tax impact of foreign-source ordinary and capital income... Read More

This CLE/CPE course will provide tax counsel and advisers with a practical discussion of IRS International Practice Unit (IPU) guidance on what constitutes "substantial compliance" in filing Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. The panel will de... Read More

This CLE/CPE course will provide counsel and tax advisers with guidance on available options for reporting foreign assets of noncompliant U.S. taxpayers. The panel will discuss Foreign Bank Account Report (FBAR) requirements, alternative compliance options, current challenges facing noncompliant tax... Read More

This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of Canadian tax considerations for U.S.-based taxpayers. The panel will discuss the Canadian tax system as applied to U.S.-based taxpayers, doing business in Canada considerations, acquisitions and financing Canadian oper... Read More

This CLE/CPE course will provide tax counsel with a comprehensive and practical guide to a deep exploration into the reporting regime for U.S. taxpayers' ownership of foreign trust assets on IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts.... Read More

This CLE/CPE webinar will provide estate planners with a comprehensive guide to tax planning challenges and opportunities for clients who have a tax presence in both the U.S. and Australia. The panel will discuss the U.S. tax law and treaty provisions that govern tax and fiduciary rules in both Aust... Read More

This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign information reporting forms, their ass... Read More

This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of the tax and operational impacts of foreign entity selection for individuals owning controlling interests in international businesses. The panelist will discuss the tax issues that arise in foreign entity selection, wit... Read More

This CLE/CPE course will guide tax professionals and advisers on the tax challenges and reporting obligations of U.S. shareholders of passive foreign investment companies (PFICs) under current tax law. The panel will discuss key tax provisions impacting the reporting of income from PFICs by U.S. tax... Read More

This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and issued guidance. The panel will discuss income-sourcing standards, the impact on digital services taxes, sourcing of inclusions under Sections 951, 951A, and 1293, and other... Read More

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of the U.S. tax implications of international joint ventures and partnerships. The panel will discuss key federal and state tax considerations and pitfalls to avoid, key tax provisions and deal points when structuring an... Read More

This CLE/CPE course will provide tax counsel and advisers with the guidance necessary to maximize the powerful tax benefits of the interest charge domestic international sales corporation (IC-DISC). The panel will review the complex requirements of applicable IRC sections, formation best practices,... Read More

This CLE/CPE webinar will provide tax counsel an in-depth analysis of methods to repatriate previously untaxed foreign earnings under current tax law. The panelist will offer tactics to mitigate taxes paid by controlled foreign corporation (CFC) shareholders, Section 965 issues, Section 245A dividen... Read More

This CLE/CPE webinar will provide tax professionals with an in-depth analysis of IRS final foreign tax credit regulations and recent guidance. The panel will discuss income-sourcing standards, the impact on digital services taxes, rules relating to foreign-derived intangible income (FDII), determina... Read More

This CLE/CPE course will guide tax counsel and advisers on the implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law. The panel will discuss key tax provisions and regulations causing compliance issues for U.S. taxpayers,... Read More

This CLE/CPE webinar will provide tax advisers with guidance on the advantages and pitfalls of using the "check the box" election for foreign LLCs and disregarded entities. The panel will discuss the tax impact of specific elections of income from foreign disregarded entities and outline tax timing... Read More

This CLE/CPE course will guide tax counsel and professionals on tax challenges and opportunities in utilizing partnerships for inbound and outbound transactions. The panelist will discuss key provisions impacting inbound and outbound transactions under current U.S. tax law, effectively using partner... Read More

This CLE/CPE webinar will provide tax counsel and advisers guidance on utilizing the Interest-Charge Domestic International Sales Corporation (IC-DISC) and Foreign-Derived Intangible Income (FDII) export tax incentives and circumstances where both may be used by taxpayers. The panelist will discuss... Read More

This CLE/CPE webinar will provide tax counsel and advisers guidance on notable changes and key issues of final IRS and Treasury qualified foreign pension funds regulations regarding gains or losses attributable to dispositions of U.S. real property interests. The panel will discuss modifications to... Read More

This CLE/CPE course will provide tax counsel and advisers with a detailed guide to preparing and filing a foreign financial institution (FFI) agreement. The panel will describe the FFI designation in depth, outline the due diligence and reporting requirements of a participating FFI, and discuss the... Read More

This CLE/CPE webinar will provide tax counsel and advisers with an in-depth analysis of the tax treatment of foreign branches of U.S.-based companies under current tax law. The panel will discuss what constitutes a foreign branch, reporting obligations, foreign tax credits, recent 267A anti-hybrid r... Read More

This CLE/CPE course will provide tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel will discuss new and significant changes to international taxation relating to the disposition of U.S. partnership interests owne... Read More

This CLE/CPE course will provide persons who have taken advantage of Puerto Rico Act 60 (formerly Act 20 and 22) and their tax advisers with guidance on managing an IRS examination and audit on grantees. The panel will also discuss the favorable treatment for Puerto Rico-source income and areas of l... Read More

This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of effective methods and challenges in resolving international tax compliance issues and disputes. The panel will discuss critical tax compliance issues stemming from Forms 3520/3520-A and 5471, navigating FBAR assessment... Read More

This CLE/CPE course will provide counsel and tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets and assisting clients with developing programs that provide workable solutions. Read More

This CLE/CPE course will provide counsel and tax advisers with guidance on available options for reporting foreign assets of noncompliant U.S. taxpayers. The panel will discuss Foreign Bank Account Report (FBAR) requirements, alternative compliance options after the IRS' termination of the Offshore... Read More

This CLE/CPE course will provide tax counsel and advisers with a thorough and practical guide into the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in India, as well as India citizens with U.S. tax reporting obligations. The panel will discuss U.S.... Read More

This CLE/CPE course will provide tax counsel with a critical analysis of IRS foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the regulations, additional "buckets" of foreign income grouping, allocation and apportionment rules, limitations under Sectio... Read More

This CLE/CPE course will provide a deep dive into the planning opportunities and reporting requirements for U.S.-based trusts that must file as non-domestic trusts for income tax purposes. The panel will discuss what constitutes "substantial decisions by non-U.S. persons" for trusts, structuring con... Read More

This CLE/CPE course will provide tax attorneys and counsel with a practical guide to removing the "taint" of foreign investments treated as passive foreign investment companies (PFICs). The panel will discuss new final and proposed PFIC regulations, the complex qualified electing fund (QEF) election... Read More

This CLE/CPE course will provide tax counsel and private investment professionals with a practical guide to structuring investments by private equity and venture capital funds (PEVC funds) in a manner that seeks to address the various tax sensitivities of PEVC fund investors. Read More

This CLE/CPE course will provide critical analysis of the IRS regulations under Section 385 to reclassify certain related-party debt as equity for U.S. tax purposes. The panel will discuss the regulations' scope, examine what types of structures and transactions are subject to reclassification as eq... Read More

This CLE/CPE course will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e). Read More

This CLE/CPE course will provide tax counsel and advisers guidance on the rules and reporting requirements for Section 250 tax deduction for foreign-derived intangible income (FDII). The panel will discuss new IRS regulations, identifying deduction-eligible income (DEI) and foreign-derived deduction... Read More

This CLE/CPE course will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes. The panelist will discuss the impact of new tax law on expatriation planning techniques, critical challenges under Section 877A, and guidance o... Read More

This CLE/CPE course will provide tax counsel and professionals an in-depth analysis of the challenges of repatriation tax audits and techniques for handling IRS enforcement actions. The panel will discuss recent IRS initiatives and standards for the repatriation of foreign sourced income, calculatin... Read More

This CLE/CPE course will provide tax counsel and advisers a critical analysis of FBAR examination, procedures, and litigation. The panel will discuss key compliance traps for foreign asset reporting, IRS guidance and relief for certain taxpayers, and new cases with issues of first impression relatin... Read More

This CLE/CPE course will provide tax counsel and advisers with a comprehensive guide to the tax and investment planning challenges and opportunities for high net worth foreign clients seeking to immigrate to the United States. The panel will discuss strategies for minimizing the U.S. tax impact of f... Read More

This CLE/CPE course will guide tax professionals and advisers on critical tax presence and residency issues for individuals and businesses stemming from COVID-19. Read More

This CLE/CPE course will provide tax counsel with a solid overview and explanation of key tax treaty provisions that tax counsel must master in structuring cross-border transactions. The panel will focus on individual, small business, and middle-market positions and will enable tax counsel to advise... Read More

This CLE/CPE course will provide tax practitioners a critical analysis of the new IRS final and proposed regulations on foreign tax credits. The panel will discuss the impact of the final rules on tax planning for foreign income, the allocation of expenses, GILTI, NOLs, and assigning foreign taxes o... Read More

This CLE/CPE course will provide tax professionals and advisers with a practical guide to the recently issued IRS final regulations on the base erosion and anti-abuse tax (BEAT). The panel will discuss critical provisions of the new IRS final regulations, application to pass-through entities, determ... Read More

This CLE/CPE course will guide tax professionals and advisers on recent directives of the European Union (EU) regarding mandatory reporting obligations for intermediaries and taxpayers. The panel will discuss the implications of the EU directive on U.S. companies, required disclosures of tax arrange... Read More

This CLE/CPE course will provide tax counsel with a detailed and practical guide to the rules governing contributions by U.S. persons to "related foreign partnerships," particularly in the wake of new IRC 721(c) Treasury Regulations, which effectively end non-recognition treatment of partnership con... Read More

This course will provide tax counsel and advisers with a thorough and practical guide to strategies for administrative challenges and defenses against penalty assessments for FBAR violations. The panel will contrast the penalty structures between FBAR and other foreign-related information filings an... Read More

This CLE course will provide tax counsel with a practical guide to navigating the IRS rules governing sales transactions involving controlled foreign corporation (CFC) stock. The panel will discuss the IRC 901(m), limitations on foreign tax credit benefits of a Section 338(g) election for buyers of... Read More

This CLE/CPE course will provide tax counsel and advisers with guidance for clients with offshore holdings who may fall under the scope of the "Panama Papers" or similar disclosure of shelter holdings. The panel will discuss due diligence requirements and processes, disclosure strategies, Offshore V... Read More