Overview
This specialized one-day Virtual Conference will explore the latest updates and planning strategies that impact cross-border tax planning, including Customs laws and issues. Our expert speakers will also discuss recent and pending legislation, with an emphasis on meeting the challenges of tax planning and conducting international business in a post-COVID world.
AGENDA HIGHLIGHTS
International Taxation Update
• Taxation of foreign source income; new developments
• Hybrid transactions
• Changes in tax laws of various foreign jurisdictions with an emphasis on Europe after BEPS and
ATAD II
• DAC 6 and ATAD II adopted by the European Commission
Transfer Pricing Update
• BEPS as a catalyst for the Tax Cuts & Jobs Act
• Impact of disclosure through Country-by-Country reporting and documentation
• New services pricing guidance
• Strategies for managing US and “Rest-of-OECD” transfer pricing policies
• The groundwork for updated financial transactions rules
Customs Issues & Laws
• Customs Informed Compliance and Reasonable Care
• Customs rulings and legal opinions
• Bases of Customs Valuation (Appraisement)
• First Sale Rule
• Duty Reduction Programs
LEARNING OBJECTIVE To update financial professionals who deal with international operations on the latest developments for
cross-border tax planning in a post-COVID world.
PREREQUISITE None. ADVANCE PREPARATION None. PROGRAM LEVEL Update. NASBA FIELD OF STUDY Taxes.
DELIVERY METHOD Group Internet-Based.
Agenda
CONFERENCE AGENDA
Welcome & Opening Remarks
8:45 – 9:00 AM
Meeting Today’s International Tax Challenges
9:00 – 9:30 AM
An expert will discuss the challenges faced by global businesses in cross-border tax planning in light of the latest developments in tax legislation, litigation, regulations and rulings in various tax jurisdictions.
Break
9:30 – 9:35 AM
International Taxation Update
9:35 – 10:50 AM
• Biden tax plans
• Taxation of foreign source income—New Developments
• Code §245A and deducting foreign-source dividends received (including hybrid transactions)
• Treatment of sales or transfers of stock in foreign corporations (Code §1248)
• Expansion of Subpart F: new ownership rules and changes to attribution rules
• Global Intangible Low-Tax Income (GILTI)
Break
10:50 – 10:55 AM
International Taxation Update (continued)
10:55 AM – 12:00 PM
• Code §250 deduction available for GILTI and Foreign Derived Intangible Income (FDII)
• High tax exception election
• Code §962 election and subsequent distributions
• Changes in tax laws of various foreign jurisdictions with an emphasis on Europe after BEPS and
ATAD II
• European attacks on state aid
• DAC 6 and ATAD II adopted by the European Commission
• The Danish cases in the European Court of Justice
Lunch
12:00 – 1:00 PM
Transfer Pricing Update
1:00 – 3:00 PM
• BEPS as a catalyst for the Tax Cuts & Jobs Act after Altera and Amazon
• Impact of disclosure through Country-by-Country reporting and documentation
• The creation of “value creation”
• New OECD intangible asset definition in action, “hard to value” intangibles
• New services pricing guidance
• Strategies for managing US and “Rest-of-OECD” transfer pricing policies and controversy
• The groundwork for updated financial transactions rules and “BEPS 2.0”
Break
3:00 – 3:15 PM
Customs, Issues & Laws
3:15 – 5:00 PM
• Customs Informed Compliance and Reasonable Care
• Customs entry requirements and procedures
• Customs rulings and legal opinions
• Customs classification
• Bases of Customs Valuation (Appraisement)
• First Sale Rule
• Countervailing and antidumping duties
• Duty reduction programs: NAFTA, other free trade area agreements, drawback
• Trump tariffs: steel, aluminum, and automobile tariffs, and Section 301 tariffs against China: how to
cope, what to do, how to file exemptions
Conference Ends
5:00 PM
Speakers
CONFERENCE SPEAKERS
Andrea Adler, Director, Valentiam Group
Galia Antebi,Member (Partner), Ruchelman PLLC
Stanley Ruchelman, Chairman, Ruchelman PLLC
David Talakoyb, Partner, Valentiam Group
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