Outbound International Taxation and Planning for the Closely Held Business (741)

General Description:

The participant will learn the fundamental reporting requirements for a U.S. person forming a foreign entity (outbound).

Learning Objectives:

After completing this course the participant will be able to:

• Contrast the difference in planning structures between a closely held structure and a publicly traded company.
• Describe how to structure a foreign entity properly in order to retain the foreign tax credit.
• Recognize the check-the-box issue to foreign entity tax classifications.
• Compare deferral strategies to loss of the foreign tax credit.
• Identify issues with the following anti-deferral regimes:
• Controlled foreign corporations;
• Passive foreign investment companies; and
• Global Intangible Low-Taxed Income.
• Explain why limitation of benefit clauses generally prevent closely held companies from treaty shopping.
• Identify countries with favorable tax treaties and answer the question, “How did Google do it?”
• Recognize tax pitfalls when contributing property to a foreign corporation under §367.
• Apply ethical considerations of undisclosed foreign assets and unreported foreign income.
• Explain foreign currency translation Issues.
• Identify attribution issues related to filing requirements.

Instructors:

Mark Merric is a CPA and an attorney and holds a master of taxation degree. He is an adjunct professor at the University of Denver Graduate Tax Program and the University of Colorado Denver MS in Taxation program, and a lecturer for Fudan University’s Master of Taxation program (second ranked in China). He manages his own law firm where he concentrates on domestic and international business transactions, international taxation, and estate planning. He has spoken nationally and internationally more than 600 times, authored and co-authored more than 80 articles nationally, and is quoted in the Wall Street Journal, Forbes, and the Boston Herald.

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