PLI’s Basics of International Taxation 2019 - Cleveland | 23 July 2019 | Cleveland Metropolitan Bar Association, 1375 E 9th St #2, Cleveland, OH 44114, 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 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

John D. Bates
Deloitte Tax LLP

Anne G. Batter
Baker &McKenzie LLP

William J. Corcoran
Cooley LLP

Ninee S. Dewar
PwC

Ligeia M. Donis
PwC

David L. Forst
Fenwick & West LLP

Corey M. Goodman
Cleary Gottlieb Steen & Hamilton LLP

Kimberly T. Majure
KPMG LLP

Jose E. Murillo
EY

Jeremy M. Naylor
Proskauer Rose LLP

Frank Y. Ng
EY

Caroline H. Ngo
McDermott Will & Emery LLP

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

Danielle E. Rolfes
KPMG LLP

Andrea Sharetta
Dentons US LLP

John P. Warner
Buchanan Ingersoll & Rooney PC

Steven C. Wrappe
Grant Thornton LLP

Philip B. Wright
Bryan Cave Leighton Paisner LLP

Lisa M. Zarlenga
Steptoe & Johnson LLP