Basics of International Taxation 2024 | Practising Law Institute (PLI) | 23 July 2024 | PLI New York, 1177 6th Ave, New York, NY 10036, USA

Why You Should Attend

In a global business environment, transactions with customers and suppliers often transcend national borders, and investment and activities are frequently cross-border as well. An understanding of the U.S. international tax rules, especially after enactment of the 2017 Tax Act, is of paramount importance to a wide variety of tax and corporate professionals.

This year’s program will be led by international tax experts and focuses on specific types of outbound and inbound investment and activities, and their U.S. tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the new U.S. tax rules address these issues. Special attention will be given to the ways the U.S. tax rules impact financings, mergers, acquisitions, and other commercial activities.

What You Will Learn

After completing this program, participants will be able to:
• Distinguish between situations where a U.S. investor should structure a foreign corporation to operate directly, and those where they should form a separate entity, under the changes made by the 2017 Tax Act
• Identify the types of expenses that can be allocated to gross income
• Apply foreign tax credit baskets to the foreign income of U.S. shareholders in a controlled foreign corporation (“CFC”)
• Recognize the impact of the sale of CFC stock on the repatriation of earnings of a foreign corporation
• Identify foreign corporations whose U.S. owners are not subject to U.S. tax until a dividend

Who Should Attend
Corporate, law firm and accounting firm professionals that consider cross-border transactions and need a working knowledge of relevant U.S. international tax rules, and government attorneys who want to stay on top of what’s happening in the international tax arena will benefit from attending this program.

2024 Speakers

CHAIRPERSONS:

Corey M. Goodman
Davis Polk & Wardwell LLP

John L. Harrington
Dentons US LLP

SPEAKERS:

Michele J. Alexander
Barnes & Thornburg LLP

Allison K. Baker
Internal Revenue Service

John D. Bates
Deloitte Tax LLP

Kevin J. Brogan
KPMG LLP

Amy K. Chapman
KPMG LLP

Ryan M. Connery
Internal Revenue Service

Jeffrey P. Cowan
Internal Revenue Service Independent Office of Appeals

Andrew T. Davis
Cravath, Swaine & Moore LLP

Moshe A. Dlott
Internal Revenue Service

Brittany N. Dobi
Internal Revenue Service

Kirk Bennett Johnson
Internal Revenue Service

Logan M. Kincheloe
Alvarez & Marsal Tax, LLC

Bradford E. LaBonte
McDermott Will & Emery LLP

Enrica Ma
EY

Elena M. Madaj
Internal Revenue Service

Michelle L. Ng
Internal Revenue Service

James S.H. Null
Loeb & Loeb LLP

Pierce W. Pandolph
Internal Revenue Service

Janicelynn A. Park
Proskauer Rose LLP

Larry R. Pounders
Internal Revenue Service

Elizabeth Sani Nelson
PwC

Gary Scanlon
KPMG LLP

Caren S. Shein
Deloitte Tax LLP

Aliza Slansky
Davis Polk & Wardwell LLP

Elizabeth J. Stevens
Caplin & Drysdale, Chartered

Amanda Pedvin Varma
Steptoe LLP

John P. Warner
Buchanan Ingersoll & Rooney PC

Richard Williams
Dentons US LLP

Steven C. Wrappe
Grant Thornton LLP

Elizabeth A. Zaitzeff
Internal Revenue Service

Z. Jack Zhou
Internal Revenue Service