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TAXATION OF INCOME EARNED BY FOREIGN SUBSIDIARIES:
Subpart F and Passive Foreign Investment Companies (PFICs)
A Live Two-Hour Audio Seminar from CCH
Tuesday, May 4, 2010 - 1 PM Eastern; Noon Central; 11 AM Mountain; 10 AM Pacific
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
Invite Colleagues, Customers, Prospects and Business Referral Sources to Join You!
Learn the Best Strategies for Dealing with Subpart F Income and PFICs
Many U.S. taxpayers erroneously think that they do not have to pay U.S. taxes on income earned by their foreign subsidiaries. There are two major exceptions to deferral of income earned by foreign subsidiaries – the Subpart F and the Passive Foreign Investment Company ("PFIC") regimes. Both of these regimes constitute traps for the unwary, who may unknowingly be subject to taxes and penalties for failure to comply.
Presented by highly-regarded international tax practitioner, Robert J. Misey, J.D., LL.M., M.B.A., this two-hour audio seminar on Tuesday, May 4, will help you become more aware of the potential pitfalls presented by income earned from foreign subsidiaries. Mr. Misey will focus on the identification, taxation and reporting of Subpart F income and the role of PFICs in your or your clients’ corporate structure. The presentation time will include opportunities for you to ask questions directly to Mr. Misey via phone and e-mail.
Program Topics
Topics to be addressed include:
- Determination of whether a foreign corporation is a controlled foreign corporation ("CFC")
- How to structure ownership so that a foreign corporation is not a CFC
- Identification of Subpart F income for inclusion on a U.S. taxpayer's return
- Use of the exceptions to avoid including Subpart F income
- Understanding the inclusion for investment in U.S. property, including the pledge of foreign assets
- Reporting Subpart F income on Form 5471
- Determination of whether a foreign corporation is a PFIC
- Understanding the two alternatives by which PFICs can be taxed
- Reporting for PFICs on Form 8621
Learning Objectives
- Understand the principles surrounding the taxation of income earned by foreign subsidiaries
- Understand how to identify, exclude and report Subpart F income
- Understand how to identify and report PFIC income
Who Should Attend?
Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys and financial advisors who work with and advise businesses that have cross-border operations, activities and issues.
SPECIAL GIFT!
Register today for this insightful program on Tuesday, May 4 at 1 PM Eastern, Noon Central; 11 AM Mountain; 10 AM Pacific.
About the Speaker:
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ROBERT J. MISEY, JR., J.D., LL.M., M.B.A.
Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and co-chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment.
For U.S. based multinationals, Rob helps clients maximize foreign tax credits and avoid U.S. taxation of foreign earnings to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob’s significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts.
Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Five accounting firm.
Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs across the U.S., Puerto Rico, the U.S. Virgin Islands, Austria, Finland, the Czech Republic and Canada. He has published numerous articles and is a co-author to the treatise, U.S. Taxation of International Transactions, published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system.
Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar. |
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
Visit CCHGroup.com/AudioSeminars for more audio seminar topics, dates and times!
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Earn CPE Credit
- Two hours of CPE credit. One free CPE certificate for one person is provided with each site registration. CPE certificates are available for $25 each for each additional person wishing to receive CPE credit for their participation.
- Course Level: Intermediate
- NASBA Field of Study: Taxes
- Prerequisites: Basic knowledge of U.S. international income taxation
- Learn More About CCH’s NASBA Registration
Special Gift
Each registered site will also get a free issue of CCH’s International Tax Journal.
Order CD Recordings of CCH Audio Seminars
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
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Site License: $249 — Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. Each Site License registration includes one free CPE certificate for one person at your site. Additional CPE certificates are available for $25 each for each additional person wishing to receive CPE credit for their participation.
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CD Recording: $249 — The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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Site License and CD Recording Package: $349 — This specially-priced package provides you with the Site License access to the live audio seminar event AND the CD Recording.
Our Guarantee
If for any reason you are not completely satisfied with this program, we will provide a full refund - no questions asked!
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
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