Events Search
  Summary & Check Out (0)
Wednesday, January 17, 2024 Live Webcast

International Tax Boot Camp (E2401360)

9:00 AM - 5:10 PM EST
webcast

Vendor Platform

8 CPE Credits in TX

OVERVIEW

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
Arthur J. Dichter, JD, LLM - Berkowitz Pollack Brant
Shawn P. Wolf, Esq. - Bilzin Sumberg Baena Price & Axelrod

  • 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)
Arthur J. Dichter, JD, LLM - Berkowitz Pollack Brant
Shawn P. Wolf, Esq. - Bilzin Sumberg Baena Price & Axelrod

  • 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
Carlos Somoza, JD, LLM - Kaufman Rossin & Co, PA
Shawn Wolf, Esq., Bilzin Sumberg Baena Price & Axelrod

  • 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)
Carlos Somoza, JD, LLM - Kaufman Rossin & Co, PA
Shawn Wolf, Esq., Bilzin Sumberg Baena Price & Axelrod

  • 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

INSTRUCTOR

Various Speakers

Various Speakers
(4.5)

PRICING

$370.00 - Member

$520.00 - Nonmember

Pre-Registration Closed

Online pre-registration for this event is now closed.

ADDITIONAL OPTIONS

Print a registration form

COURSE DEVELOPER

FICPA/NJCPA