Gain a better understanding of the issues related to foreign operations, creating U.S. ownership, repatriating earnings, and maintaining compliance with U.S. tax law.
Foreign operations can present a significant opportunity for a U.S. company, but can also raise a number of U.S. tax issues. Proper tax planning in establishing foreign operations, and an understanding of the ongoing disclosure and other requirements they require, is essential to avoiding problems down the road.
This material will provide you with an overview of the issues (and highlight some potential pitfalls) related to foreign operations, creating U.S. ownership, repatriating earnings, and maintaining compliance with U.S. tax law and disclosure requirements and keeping current on recent tax legislation.
Learning Objectives:
- You will be able to discuss U.S. issues and decisions to make for foreign operations.
- You will be able to identify U.S. disclosure requirements for foreign operations.
- You will be able to review U.S. ownership issues related to a choice of business entity.
- You will be able to describe the recent tax legislation that impacts foreign entities.
Establishing Foreign Operations
• Choice of Entity
• Local Taxes and Credits
• Foreign Operations and Issues
• Distribution of Earnings
Consequences of U.S. Ownership
• Disclosure of U.S. Ownership
• Subpart F Definitions and Issues
• Anti-Deferral Rules
Tax Reporting and Disclosure Issues
• U.S. Tax Withholding and Treaties
• U.S. Disclosure Requirements
• Transfer Pricing Issues
New Issues Under Recent Tax Legislation
• Territorial System
• Mandatory Repatriation
• Low-Taxed Intangibles Income
• Export Incentive
Credit Information (Sponsored by Lorman Education Services):
- CLE
- CPE
- AIPB
- NASBA
For Detailed Credit Information page
click here
Only registered attendee will receive continuing education credit.
Faculty
Thomas M. Kosinski, C.P.A., M.S.T., Ostrow Reisin Berk & Abrams, Ltd.
- Has been with Ostrow Reisin Berk & Abrams, Ltd., since 1994, and became a director in 2001
- He has more than 12 years of experience offering strategic tax planning and technical advice for individuals and the owners of closely held companies
- Provides the full range of specialized services to his clients, which include high net worth individuals and business entrepreneurs
- Has significant experience in the commodities and securities industry
- Researched and implemented a wide range of federal and Illinois tax strategies, assisted with tax consulting for individuals and corporations, and represented numerous Illinois taxpayers during IRS and Illinois Department of Revenue audits
- Is the firm’s primary consultant on state and local taxation issues and has experience with tax issues relating to international taxation
- Has also assisted U.S.-based entities in planning for foreign operations as separate entities, branches or divisions
- An active member and a former president of the Illinois CPA Society Chicago South Chapter and is also a member of the American Institute of Certified Public Accountants; in addition, he is a contributing writer for a tax newspaper column and previously was a co-author for a tax savings publication for individual taxation Master’s degree in taxation and B.S. degree in accounting, summa cum laude, DePaul University
(Not available outside the US)