Conference Program
Thursday, January 24, 2013
Introduction to International Taxation Issues
8:00 a.m.–8:30 a.m.
Check-In and Continental Breakfast
8:30 a.m.–8:40 a.m.
Welcoming Remarks
Committee Chair:
Melissa S. Gillespie, CPA, MST, JD, Law Offices of Melissa Gillespie
Conference Cochairs:
Peter Baum, CPA, Tax Partner, Citrin Cooperman
George Deely, CPA, Tax Manager, Shanholt Glassman Klein Kramer & Co. P.C.
8:40 a.m.–9:30 a.m.
U.S. Taxation of Foreign Earnings
Nancy Berk, CPA, Sole Practitioner
Ms. Berk will discuss the critical U.S. international tax rules that are applicable to U.S. corporations and individuals engaged in overseas operations that practitioners need to be aware of in advising their international clients.
9:30 a.m.–10:20 a.m.
Complying with the IRS Regulations
Brian Skarlatos, Esq., Partner, Kostelanetz & Fink, LLP
It seems that every other client has foreign assets these days. Yet many of those clients have failed to properly report those assets to the IRS. What is and is not required under the law to correct a taxpayer’s failure to report foreign assets? Is the Offshore Voluntary Disclosure Program the best choice for your client, and how has the IRS changed its approach with the latest OVDP? This program will review your options for bringing your clients into compliance.
10:20 a.m.–10:30 a.m.
Break
10:30 a.m. –11:20 a.m.
Computing Earnings & Profits
Philip T. Pasmanik, CPA, Senior Tax Manager, Crowe Horwath LLP
Learn to understand the concept of Earnings and Profits (E&P), what it impacts, including related adjustments-domestic calculations. The session will explain why determining a foreign corporation’s E&P is a must-know in many transactions, because E&P often controls the result of such issues as the amount of income recognized, its timing, as well as character. Topics covered will include, the layering and pooling of E&P, the effect of distributions, currency translation, and reporting and record-keeping requirements.
11:20 a.m.-12.10 p.m.
Introduction to Form 1120-F
Tobias F. Zeigler, Esq., Partner, Gallet Dreyer & Berkey, LLP
Learn what it means to be doing business in the United States. Which foreign businesses have to file Form 1120-F? What is “effectively connected income?” What reporting is required? Pitfalls that businesses should consider when choosing branch/single member LLC and partnership structures.
12:10 p.m.–1:10 p.m.
Lunch
1:10 p.m.–2:20 p.m.
Concurrent Sessions: (Choose one)
An Overview of the Withholding Rules & W-8 series and 8804/05 Series
Jim Booth, CPA, Partner, D’Arcangelo & Co., LLP
Learn the distinctions between IRC Sec 1441, 1442, and 1446 withholding regimes. Mr. Booth will also discuss withholding related to income covered by tax treaty and that related to “effectively connected income.”
This session will be webcast live.
An Introduction to Estate and Gift Taxation as It Relates to Non-Resident Aliens
Kevin Matz, Esq., Partner, Kevin Matz & Associates PLLC
A review of the fundamental principles of Trust and Estate taxation as it relates to non-resident aliens including the utilization of a qualified domestic trust (QDOT). There will be a discussion of various planning techniques to enable nonresident aliens to reduce or eliminate their exposure to U.S. estate and gift tax, as well as the generation-skipping transfer tax.
2:20 p.m.–3:10 p.m.
Understanding the Foreign Tax Credit
Mitchell Sorkin, CPA, MBA, Tax Partner, Raich Ende Malter & Co. LLP Company
Learn the intricacies of the foreign tax credit computation, the significance of the classification of income, passive, general limitation, and long-term capital gains rate. Learn how foreign net operating losses affect the credit.
3:10 p.m.–3:20 p.m.
Break
3:20 p.m.–4:10 p.m.
U.S. Taxation of U.S. Citizens Working Abroad (Expatriation Taxation-1040)
Marc J. Strohl, CPA, Principal, Protax Consulting Services Inc.
Learn about the general concepts of U.S. taxation versus other countries as it pertains to tax residence, and about the Foreign Earned Income Exclusion and Housing Deduction and how the exclusion and foreign tax credit interplay.
4:10 p.m.–5:00 p.m.
U.S. Taxation of Nonresidents Working in the U.S. (Inpatriation Taxation-1040NR)
Susan Brown Otto, CPA, International Tax Advisory Services, LLC
Brief REview of who is a resident and nonresident US Federal Tax Alien, including a review of form 1040NR & instructions. Review of miscellandous forms and topics, including current events and highlights of alien tax matters experienced this past year.
Friday, January 25, 2013
Intermediate/Advanced Issues
8:00 a.m.–8:45 a.m.
Check-In and Continental Breakfast
8:45 a.m.–9:00 a.m.
Welcoming Remarks
9:00 a.m.–9:50 a.m.
How do the Foreign Account Tax Compliance Act (FATCA) Withholding Regulations Affect Your Clients
Michael Sardar, Kostelanetz & Fink
Gain an understanding of the impact which the new FATCA withholding regulations will have on your clients. FATCA’s central purpose is to identify U.S. taxpayers who hold financial assets in non-U.S. financial institutions and other offshore accounts, so that they cannot avoid their U.S. tax obligations. Be prepared so you can advise your clients what to expect when these withholding regulations are implemented.
9:50 a.m.–10:40 a.m.
Doing Business Overseas, Choice of Entities, and Overlay of Treaties
Stanley C. Ruchelman, JD, Partner, The Ruchelman Law Firm
Tax advisors planning a cross-border investment often suggest that taxes can be lowered if an investment is made through a company that is a tax resident in a jurisdiction having an income tax treaty with the U.S. However, access to treaty benefits has become more difficult to achieve, as mere tax residence in a treaty country is not enough for a corporation to claim treaty benefits. This session will address the range of tax benefits that are derived under treaties, the hurdles that are required to claim those benefits, and the interplay of treaty benefits and the entity classification (“check-the-box”) rules of the income tax regulations.
10:40 a.m.–10:50 a.m.
Break
10:50 –11:50 a.m.
Concurrent Sessions: (Choose one)
A. Doing Business Abroad in Corporate Form: Outbound Asset Transfers to a Foreign Corporation – IRC Sec. 367(a) and 367(d)
Paul Dailey, CPA, MBA, Tax Principal, Rothstein Kass & Company P.C.
How to qualify an outbound transfer of assets to a foreign subsidiary or joint venture as tax-free under Sec 367(a), along with a review of the rules for transfers of intangibles under Sec 367(d).
This session will be webcast live.
B. U.S. Taxation of Offshore Life Insurance
Steven Zeiger and Sam Rayden, NFP National Madison
Practitioners will learn planning techniques utilizing tax favored offshore private placement life insurance and annuities as supported by IRC 7702. Practitioners will learn how to advise their clients about PPLI in the U.S. and offshore marketplace.
11:50 a.m.–12:50 p.m.
Lunch
12:50 p.m.–1:50 p.m.
Concurrent Session (Choose One)
C. Doing Business Abroad in Branch or Partnership Form: Dual Consolidated Losses
Mitchell Siegel, CPA, International Tax Services, Deloitte Tax LLP
This session will include a discussion of the U.S. tax implications of operating overseas through a flow-through entity. Ownership of non-U.S. flow-through entities by PFICs, CFCs, and U.S. persons will be discussed. The status of the proposed Sec. 987 regulations, newly enacted FTC provisions, as well as an update on the Dual Consolidated Loss provisions will be included in this discussion.
This session will be webcast live.
D. Expatriation rules pursuant to IRC Sec. 877A.
Jack Meola, CPA, Partner, Eisner Amper LLP
Determine if your client will be subject to the complex expatriation rules as provided under IRC 877A and, if so, learn how to navigate these rules in order to properly calculate the expatriation tax. Explore planning techniques to avoid being subject to these rules.
1:50 p.m.–2:40 p.m.
Understanding the Sourcing Rules for Determining Foreign Source Income
Peter Stratos, CPA, Partner, Stratos & Associates Pllc
Understand the sourcing rules as set forth in IRC Secs. 861, 862, 863, 865, and 884. Learn the significance of predominant situs of the economic activity as well as the “split-source” rules.
2:40 p.m.–2:50 p.m.
Break
2:50 p.m.–3:40 p.m.
Review of Subpart F Income
Richard Goldstein, CPA, Partner, Buchbinder Tunick & Company, LLP
Magda Szabo, JD, LLM, CPA, Director, Perelson Weiner LLP
Overview of Subpart F income and recent developments, including active business income, same country exception, active financing exception, contract manufacture (including the branch rule), hybrid branch payments, Brown Group regulations, and repatriation issues.
3:40 p.m.–4:15 p.m.
International Tax Update
Tom Butera, CPA, Deloitte Tax LLP
A summary of the most recent developments in the international taxation field along with an overview of the regulatory issues facing both domestic and foreign taxpayers.
4:15 p.m.–5:05 p.m.
U.S. Taxation of Foreign Pensions
Terry Eyberg, CPA, Senior Manager, Ernst & Young
Determining the U.S. taxation of foreign pension and retirement plans is not an easy task. There is minimal guidance from the IRS, and it seems more of our clients have such plans. Learn how foreign pension plans are to be reported and taxed on U.S. individual income tax returns. Review the related treaty provisions as provided in various income tax treaties. Review the recent IRS position on the late filed Form 8891 elections.
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