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Events

Nov
7
12:00 PM12:00
CPE, CLE

Biases, Heuristics, Blind Spots, and Pitfalls in I.R.S. Transfer Pricing Exams

When a taxpayer receives an information document request (“I.D.R.”) from the I.R.S. for transfer pricing documentation, it should know what to expect: a lengthy, contentious process of documenting and defending its tax position. Pausing to think objectively about the cognitive biases, strengths, and weaknesses underlying a transfer pricing position is an essential step to take before delving into the technical aspects of the examination itself.

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A Foreign Lawyer’s Guide to U.S. International Tax Law: Core Concepts
Jul
10
5:00 PM17:00

A Foreign Lawyer’s Guide to U.S. International Tax Law: Core Concepts

The first in a two-part series, this program will address the core concepts of U.S. tax law, including these and other key issues: entity classification rules (classification of foreign entities as corporations, partnerships, and single-member L.L.C.’s for U.S. tax purposes), Controlled Foreign Corporations, Passive Foreign Investment Companies, and distributions from corporations.

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Global Law Week: B.E.P.S. Tax Panel
Jun
11
9:00 AM09:00

Global Law Week: B.E.P.S. Tax Panel

Three years have passed since the O.E.C.D./G-20 Base Erosion and Profit Shifting Project identified 15 Actions necessary for preventing loss of tax revenue through abusive, cross-border tax planning. In the interim, countries have taken action to implement these recommendations. Panelists from Brazil, India, the Netherlands, and the U.S. will explain how the B.E.P.S. Actions are applied on the ground in various regions.

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Strafford Webinar: Taxation of Foreign Source Income Under New Tax Law
May
10
1:00 PM13:00
CLE, CPE

Strafford Webinar: Taxation of Foreign Source Income Under New Tax Law

This CLE/CPE webinar will provide tax professionals guidance on new rules and regulations governing the taxation of foreign source income. The panel will present an in-depth analysis of the expansion of Subpart F, the dividends received deduction ("D.R.D."), tax implications of sales or transfers of foreign corporations by U.S. shareholders, and provide guidance on avoiding pitfalls to ensure tax savings and reporting compliance.

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F.B.A.R. Compliance and Controversy: Foreign Asset Reporting for Individuals and Entities
Mar
6
12:00 PM12:00
CLE, CPE

F.B.A.R. Compliance and Controversy: Foreign Asset Reporting for Individuals and Entities

Although some Federal priorities change, the I.R.S. continues to focus on offshore bank accounts and the obligation to report foreign assets on the Report of Foreign Bank and Financial Accounts. In this program, Rusudan Shervashidze and Lawrence S. Feld will explore the F.B.A.R. reporting regime and discuss the U.S. government's criminal and civil enforcement efforts.

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Tax Planning for Brexit & Beyond: Navigating the New European Landscape
Feb
22
6:00 PM18:00

Tax Planning for Brexit & Beyond: Navigating the New European Landscape

This program will focus on the critical issues of Eurocentric tax planning in the age of Brexit, B.E.P.S., and emboldened tax authorities. It is presented in conjunction with the Taxation of Business Entities Committee and the European Affairs Committee the New York City Bar Association and the Chartered Insitute of Taxation (CIOT).

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Trusts – Residency and Taxation
Nov
15
12:00 PM12:00
CLE, CPE

Trusts – Residency and Taxation

Trust instruments constitute a common estate planning tool in common law countries. While planning for future generations within the boundaries of a single jurisdiction constitutes the historical approach, families in today’s world do not necessarily live in the same country. This program serves as a primer on U.S. taxation of trusts having U.S. and non-U.S. settlors and beneficiaries.

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Transfer Pricing for Mid-Sized Corporations: Differences in Approaches to Planning, Documentation, and Controversy Management
Oct
17
12:00 PM12:00
CLE, CPE

Transfer Pricing for Mid-Sized Corporations: Differences in Approaches to Planning, Documentation, and Controversy Management

This program will describe the unique challenges for mid-sized companies in planning, implementing, documenting, and managing controlled cross-border transactions and in dealing with tax authority controversy. Best practices and key points for advisors will be presented to explain how a company can meet its compliance obligations while acknowledging actual business practices.

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Spanish Tax Update
May
10
12:30 PM12:30

Spanish Tax Update

This Ruchelman international tax luncheon addresses planning opportunities for Spanish investment, including well-known and little-known vehicles for structuring investments in and through Spain, such as the E.T.V.E., the S.O.C.I.M.I., and the Z.E.C. The program features guest speakers José María Cusí and Juan Roda of CHR Legal, Barcelona.

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