Tax Aspects of International Joint Ventures June 9 & 10, 2014 Houston, TX Gardere Wynne Sewell Conference Center

Transcription

1 Tax Aspects of International Joint Ventures A two day intermediate to advanced level conference with live group instruction providing an in-depth analysis of the many tax issues related to the formation and operation of an international joint venture. Benefits of Attending: Understand state and local tax considerations for joint ventures Learn special issues regarding the partnership form Lost capture rules; Sec (d) issues; Sec. 367 branch loss recapture rules Structural planning ideas to transfers of intangibles and maximization of foreign tax credits, tax treaty issues and recent IRS rulings and positions will be discussed >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Advanced International Tax Planning A two-day advanced level seminar with live group instruction will examine recent changes in the U.S. and foreign tax laws, recent court cases and tax rulings that have a major impact on doing business abroad. Benefits of Attending: Learn planning strategies for intangibles ownership Understand negotiating tax provisions drafting the in acquisitions & dispositions agreements Developments in international fi nancial transactions, including currency Learn the current issues in transfer pricing (other than intangibles) $340 off when you register for both programs at the same time! All paid attendees will receive the Bloomberg BNA Portfolio: Partners and Partnerships International Tax Aspects Portfolio #910-2nd (a $400 value) *One Portfolio per paid attendee. Quantities are limited. All paid attendees will receive the Bloomberg BNA Portfolio: Foundation of US International Taxation #900-2nd (a $400 value) *One Portfolio per paid attendee. Quantities are limited. These unique courses are offered exclusively by Bloomberg BNA FACULTY Douglas Andre Ivins Phillips & Barker Charter Bart Bassett Morgan Lewis LLP Rob Bossart Law Offi ces of Rob Bossart Alan Cathcart KPMG LLP Fred Chilton KPMG LLP George M. Clarke Adam Halpern Fenwick & West LLP Elvin Hedgpeth Ernst & Young LLP Dominika Korytek E. Daniel Leightman Gardere Wynne Sewell LLP Michael P. Liu Jonathan Martin William Skinner Fenwick & West LLP William Spiller Grant Thornton LLP Mark Yopp McDermott Will & Emery Russell R. Young

2 Tax Aspects of International Joint Ventures Day One 8:00 AM Registration and Continental Breakfast 9:00 AM Conference Welcome and Introduction 9:15 AM Joint Venture Structuring Issues Deferral options Foreign tax credit maximization Partnership agreement & partnership tax elections 10:30 AM Break for Refreshments 10:45 AM Transfer of Property to an International Joint Venture Transfers to corporations: Section 367(a) and (d) issues Transfers to Partnerships: Section 721(a), (c), and (d) 12:00 PM Luncheon 1:00 PM Partnership with U.S. and Foreign Partners Conducting Business Inside the U.S. Section 1446 withholding issues Foreign partners filing U.S. federal income tax return Sale or exchange of partnership interest Treaty issues 2:15 PM Break for Refreshments 2:30 PM State and Local Tax Considerations for Joint Ventures 3:45 PM Doing Business with the Joint Ventures Intercompany Pricing Rules of Section 482 Pricing arrangements between partner & partnership Alternative structures 4:45 PM Question & Answer Session 5:00 PM Meeting Adjourns for the Day Day Two 8:00 AM Continental Breakfast 8:30 AM CFC Partners in International Joint Ventures Subpart F Issues Anti-Brown Group regulations Special issues in foreign base company sales income Partnerships and Section 956 9:45 AM Break for Refreshments 10:00 AM Loss Recapture Rules Section 1503 (d) issues Dual consolidated loss rules Section 367 branch loss recapture rules Section 904(f) issues 11:15 AM Special Issues Regarding the Partnership Form Currency issues Section 987 Dual consolidated losses Section 752 recapture Allocation of expenses 12:30 PM Question & Answer Session 12:45 PM Meeting Adjourns Times/topics/speakers subject to change Bloomberg BNA All rights reserved All paid attendees will receive the Bloomberg BNA Portfolio: Partners and Partnerships International Tax Aspects Portfolio #910-2nd (a $400 value) *One Portfolio per paid attendee. Quantities are limited. $340 off when you register for both programs at the same time!

3 Advanced International Tax Planning Day One 8:00 AM Registration and Continental Breakfast 8:30 AM Intangibles Ownership Planning Strategies & Valuations 9:45 AM Break for Refreshments 10:00 AM Subpart F Planning Discussion of characterization of income for purposes of determining applicable foreign base company income rules Review of selected Sec. 956 issues, such as Sec. 956 (c)(2)(c) exception for CFC intercompany receivables arising in connection with sales of inventory Issues arising in connection with active royalties and rental income exceptions to FPHCI Discussion of substantial contribution rules and practical application of those rules to complex manufacturing situations Continuing substantial assistance issues where U.S. parent carries out management of servers and co-development activities under a costsharing arrangement 11:15 AM International Joint Ventures Using partnerships in an international JV Special partnership planning Planning to unwind an international JV Partnership foreign tax credits Other international partnership issues 12:30 PM Luncheon 1:15 PM Developments in International Financial Transactions, Including Currency Practical approaches for dealing with Sec. 987 Currency hedging transactions Acquisition financing strategies Other current developments affecting financing strategies 2:30 PM Cash Management Within Worldwide Group 3:30 PM Break for Refreshments 3:45 PM Current Issues In Transfer Pricing (Other than Intangibles) Global overview TP aspects of acquisitions Case update Current IRS approaches to TP 5:00 PM Seminar Adjourns for the Day Day Two 8:00 AM Continental Breakfast 8:30 AM Repatriation Strategies General update on repatriation techniques Impact of Notice on use of outbound asset reorganizations as repatriation technique Potential for regulatory or legislative change in aftermath of senate PSI hearing 9:30 AM Managing PE & Business Profits Risks Examine aggressive foreign audits on U.S. companies Focusing on bilateral income tax treaties dealing with permanent establishment and business profits Both OECD guidance and specific countries case law on these topics will be reviewed Suggestions for structuring business operations to minimize PE exposure Examine the amount of business profits taxable by the source country will be offered 10:30 AM Break for Refreshments 10:45 AM Negotiating Tax Provisions Drafting the in Acquisitions & Dispositions Agreements 12:00 PM Luncheon 12:45 PM Dealing With the APMA Program Organizational changes made to the U.S. competent authority function Impact of changes on operations Development of revenue procedure addressing both APA and MAP programs Noteworthy country developments 1:45 PM Dual Consolidated Losses Dual consolidated losses overview Domestic use limitations Filing requirements Dual consolidated lose recapture 2:45 PM Seminar Adjourns Times/topics/speakers subject to change 2014 The Bureau of National Affairs, Inc. All rights reserved. All paid attendees will receive the Bloomberg BNA Portfolio: Foundation of US International Taxation #900-2nd (a $400 value) *One Portfolio per paid attendee. Quantities are limited.

4 Five Easy Ways to Register: Web: Telephone: Facsimile: Mail: Bloomberg BNA s Customer Contact Center 3 Bethesda Metro Center, Suite 250 Bethesda, MD USA HARDSHIP POLICY Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at accreditations@bna.com. Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance. CANCELLATION POLICY If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact customercare@bna.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered no shows and will not be eligible for a refund, transfer, or substitute event. Cancellations must be made in writing to customercare@bna.com more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at , or customercare@bna.com. CPE/CLE CREDITS AVAILABLE Bloomberg BNA is registered with the National Association of the State Boards of Accountancy as a sponsor of continuing professional education on the National Registry of CPE sponsors. State Boards of Accountancy have final authority on the acceptance of individual courses. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at and ask to speak to the CLE Accreditations Coordinator, or us at accreditations@bna.com. CONFERENCE LOCATION Gardere Wynne Sewell Conference Center Louisiana St #3400, Houston, TX Hotel accommodations are at your own discretion. We suggest the following: Doubletree Downtown Tel.: Dallas St., Houston, TX Hyatt Regency Houston Tel.: Louisiana St., Houston TX Fee Includes Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio and course materials in electronic format. Contact Bloomberg BNA about discounts for three or more registrants from the same company SPONSORSHIP OPPORTUNITIES ARE AVAILABLE Contact Bloomberg BNA at customercare@bna.com or call Tax Aspects of International Joint Ventures Cannot be transferred or combined with other discounts. $1195 Early Registration (up to 1 month prior to course) $2150 Early Registration (up to 1 month prior to course) $1395 Registration (within 1 month of course) $2450 Registration (within 1 month of course) Advanced International Tax Planning $1295 Early Registration (up to 1 month prior to course) $1395 Registration (within 1 month of course) Method of Payment All credit cards converted to and billed in U.S. dollars (USD). Check enclosed payable to Bloomberg BNA Name Credit card payment: MasterCard Visa AmEx Discover All credit cards will be processed at current U.S. conversion rates Title Organization Address City State Zip Card No. Telephone Fax V-code Card exp. /Billing Zip Card Expiration Date Signature

5 Tax Aspects of International Joint Ventures WHY YOU SHOULD ATTEND Bloomberg BNA is proud to announce a new two-day seminar on Tax Aspects of International Joint Ventures. This program will focus on an in-depth analysis of the many tax issues related to the formation and operation of an international joint venture. Learn structured planning ideas relating to maximizing foreign tax credit benefi ts, transfer of intangibles, Subpart F issues and understanding the intercompany pricing and loss recapture rules. The seminar will also address state and local considerations and reporting requirements as well as currency, allocation of expenses, dual consolidated loss and treaty issues. WHO SHOULD ATTEND This session is intended for corporate tax department personnel and practitioners with an intermediate to advanced level of international experience who want joint venture issues to be identifi ed and solutions offered. This intermediate to advanced level course with group live instruction is non-transitional. An introductory to intermediate international tax seminar is a prerequisite prior to attending. Advanced International Tax Planning WHY YOU SHOULD ATTEND The focus of this seminar is on advanced tax planning. It is designed specifi cally to demonstrate strategies you can adapt now to minimize the tax bill for your company or clients. The program is designed for senior tax practitioners in corporate or private practice with prior exposure to international taxes. It will not repeat the basics but will concentrate instead on the following major current issues, and the tax planning opportunities they provide, which our consultants believe should be examined immediately to reduce the tax cost of doing business overseas: Managing PE & business profi ts risk Foreign currency developments Dealing with the new APMA program Washington update Intangible migration strategies Please take a few minutes now to examine the workshop outline, which describes the program in great detail. Due to the advanced nature of the agenda and to the extraordinary caliber of the speakers, many companies or fi rms may wish to send a team of tax professionals. Our experienced faculty will guide you through the recent IRS regulations, reporting requirements and show you practical strategies for reducing foreign and U.S. taxes for your company. Please note that additional registrants from the same fi rm are entitled to a reduced workshop fee. WHO SHOULD ATTEND This conference with live group instruction is intended for: corporate tax vice-president, corporate tax director, manager-international tax, tax counsel, treasurers, CFOs, attorneys and tax accountants involved in annual and transactional U.S. international tax planning for U.S. and foreign multinationals. This intermediate to advanced level conference is non-transitional. An introductory to intermediate international tax conference is a prerequisite prior to attending. $340 off when you register for both programs at the same time! These unique courses are offered exclusively by Bloomberg BNA

6 Bloomberg BNA s Customer Contact Center 3 Bethesda Metro Center, Suite 250 Bethesda, MD Tax Aspects of International Joint Ventures >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Advanced International Tax Planning :::::::::::::::::::::::::::::::::::::: :::::::::::::::::::::::::::::::::::::: $340 off when you register for both programs at the same time!