Introduction to International Corporate Taxation 2019 - San Francisco | Practising Law Institute (PLI) | 9 September 2019 | PLI California, 685 Market St # 100, San Francisco, CA 94105, USA

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 the issues raised. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities.

What You Will Learn?
• How the changes made by the 2017 Tax Act affect choice of entity decisions for U.S. and foreign investors
• The new 100% dividend exemption for domestic corporations owning foreign corporations
• Subpart F and new global intangible low-taxed income (“GILTI”) rules which cause U.S. shareholders in controlled foreign corporations (“CFCs”) to be subject to immediate U.S. tax
• Tax and reporting rules that apply to U.S. subsidiaries of foreign companies
• Background, purpose and history of foreign tax credits
• The mechanics and significance of tax treaties
• Overview of the reporting and withholding requirements in international transactions
• Recognizing Passive Foreign Investment Companies (“PFICs”)

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.

2019 Speakers

CHAIRPERSON:

John L. Harrington
Dentons US LLP

SPEAKERS:

Narendra Acharya
Partner, Baker &McKenzie LLP

David L. Forst
Fenwick & West LLP

Corey M. Goodman
Tax Partner, Cleary Gottlieb Steen & Hamilton LLP

Justin E. Jesse
McDermott Will & Emery LLP

Prae Kriengwatana
Director, PwC

Kimberly T. Majure
Inbound Tax Leader, KPMG LLP

Megan E. Marlin
Director, PwC

Jose E. Murillo
EY

Jeremy M. Naylor
Proskauer Rose LLP

Frank Y. Ng
EY

James S.H. Null
Eversheds Sutherland (US) LLP

Jason Robertson
Deloitte Tax LLP

Danielle E. Rolfes
KPMG LLP

Andrea Sharetta
Dentons US LLP

Steven J. Sideris
EY

Greg A. Texley
Senior International Tax Law Specialist Internal Revenue Service

Jason Vollbracht
Goodwin Procter LLP

Steven C. Wrappe
Grant Thornton LLP

Philip B. Wright
Partner, Bryan Cave Leighton Paisner LLP

Lisa M. Zarlenga
Steptoe & Johnson LLP