Bloomberg BNA Conference to Examine New Tax Reporting and Compliance Procedures for U.S. Companies with International Operations

ARLINGTON, Va., May 22, 2012 /PRNewswire-USNewswire/ -- Recent tax legislation changed tax reporting and compliance procedures for U.S. multinationals. In addition to extending tax rates, the new provisions also contain changes in the international tax provisions that may increase the U.S. tax cost of remitting foreign earnings as cash or Subpart F dividends. Bloomberg BNA | CITE will host a live conference, U.S. International Tax Planning, June 4-6 at Sentry Conference Center in New York City, that will examine the latest U.S. tax developments and tax strategies for U.S. companies with operations overseas.

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"The IRS has stepped up efforts and penalties in auditing foreign activities and operations of U.S. multinationals," said Diane Pastore, Executive Director at Bloomberg BNA | CITE.  "For 2012, tax practitioners must understand and implement new foreign tax reporting and compliance procedures in determining their tax liability."

This conference will provide guidance for understanding the new rules for interest apportionment, the latest regulations involving Subpart F FPHC income, and the new intercompany service regulations: charging for headquarter services and imbedded intangibles.

The effect of new FTC limitations on dividends under Subpart F and Sec. 956 and the use of the new statutory merger or consolidation rules for an acquisition of foreign tangible and intangible assets will also be addressed.

Various sessions will examine reporting the results of foreign operations and activities, understanding the rules for computing foreign exchange gain (loss), and computing direct and indirect foreign tax credit benefits. In addition, the conference will cover Subpart F anti-tax deferral rules, the interrelationship with the tax accounting rules (ASC 740), taxable transfers of CFC stock by U.S. shareholders, and tax-free international mergers and acquisitions under Sec. 367.

By attending the two-and-one-half day conference, attendees will:

• Find out how the latest legislative changes affect their company's tax planning and compliance strategies in 2012
• Determine the latest tax benefits and non-benefits of using a hybrid entity overseas
• Learn the latest IRS regulations affecting the treatment of foreign exchange gain (loss) recognized by non-U.S. branches and disregarded entities
• Discover how the foreign tax credit changes limit FTC benefits and affect FTC baskets and gross-up calculations
• Understand the latest expense apportionment rules for interest and R&D and how they can reduce foreign tax credit benefits
• Learn the latest Subpart F rules for foreign base company income and investments in U.S. property and strategies for remitting dividends
• Ascertain how the latest U.S. tax legislation limits FTC benefits in cross-border mergers and in Sec. 338 acquisitions
• Determine the 2012 U.S. tax consequences under Sec. 1248 of CFC sales by U.S. companies and individuals
• Find out the 2012 U.S. tax filing and compliance requirements for foreign entities and transactions
• Analyze the impact of the U.S. transfer pricing rules on foreign profits of multinationals and evaluate IRS audit exposure in reporting uncertain tax positions

U.S. International Tax Planning will take place at Sentry Conference Center in New York, NY. To register, go to www.bna.com or call (914) 328.5656 for further information on special rates.

About Bloomberg BNA 

Bloomberg BNA, a wholly-owned subsidiary of Bloomberg, is a leading source of legal, regulatory, and business information for professionals. Its network of more than 2,500 reporters, correspondents, and leading practitioners delivers expert analysis, news, practice tools, and guidance - the information that matters most to professionals. Bloomberg BNA's authoritative coverage spans the full range of legal practice areas, including tax & accounting, labor & employment, intellectual property, banking & securities, employee benefits, health care, privacy & data security, human resources, and environment, health & safety. www.bna.com

SOURCE Bloomberg BNA

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