This conference is the place to master need-to-know skills and trends in the international tax realm and is designed to prepare an attendee with a foundational understanding of international tax.
DESIGNED FOR
All levels of tax practitioners and advisors.
BENEFITS
The Boot Camp will cover the basic topics of international inbound and outbound taxation.
HIGHLIGHTS
This conference is presented by the Florida Institute of CPAs (FICPA) in cooperation with the NJCPA.
9-10:45 a.m.
International Inbound Taxation
Ryan Coyle, Counsel - McDermott, Will & Emery LLP
Arianne Plasencia, Partner - McDermott, Will & Emery LLP
- Residency, sourcing, FDAPI, ECI, FIRPTA, branch profits tax, treaties
- TCJA specific changes to inbound taxation
- Choice of entity for inbound structuring
- Base erosion and anti-abuse tax (BEAT)
10:45-11:05 a.m.
Break
11:05 a.m.-12:45 p.m.
International Inbound Taxation (continued)
Ryan Coyle, Counsel - McDermott, Will & Emery LLP
Arianne Plasencia, Partner - McDermott, Will & Emery LLP
- Interest limitation under Section 163(j)
- Treatment of gain or loss of foreign persons from sale or exchange in interests in partnerships engaged in U.S. T/B (Sections 1446(f) and 864(c)(8))
- Sourcing of inventory sales based solely on production activities (Section 863(b))
12:45-1:30 p.m.
Lunch Break
1:30-3:10 p.m.
International Outbound Taxation
Shawn Wolf, Esq., Bilzin Sumberg Baena Price & Axelrod
Carlos Somoza, JD, LL.M. - Kaufman Rossin
- TCJA specific changes to outbound taxation
- General overview of outbound taxation
- Expansion of CFC and U.S. shareholder definitions
- Elimination of 30-day rule under Section 951(a)(1)
- Repeal of downward attribution rule (Section 958(b)(4))
3:10-3:30 p.m.
Break
3:30-5:10 p.m.
International Outbound Taxation (continued)
Shawn Wolf, Esq., Bilzin Sumberg Baena Price & Axelrod
Carlos Somoza, JD, LL.M. - Kaufman Rossin
- Transition tax under Section 965
- Global intangible low-taxed income (GILTI) regime (Section 951A)
- Participation exemption under Section 245A
- Deduction for foreign-derived intangible income (“FDII”)
- Foreign tax credit buckets (GILTI and foreign branch baskets)
COURSE LEVEL
Basic