Event Registration

While tax insurance has been utilized for many years to mitigate tax risk, it remains novel for many taxpayers and practitioners. As awareness grows, so has the application of insurance to cutting edge issues and a broader range of tax matters.

This panel will take a deeper dive into:

• The use of tax insurance for international tax issues
• International tax issues relevant to high net-worth clients.
• Looking ahead at what is on the horizon in this growing area.

This presentation will address the various considerations, pitfalls, and planning opportunities applicable where a U.S. person stands to inherit, or has already inherited, assets from a nonresident alien.

This presentation will discuss:

• Dealing with the controlled foreign corporation and passive foreign investment company regimes.
• Double tax issues.
• Obtaining a basis set-up in the inherited assets
• Trust planning

This panel will cover various strategies for non-US persons to consider when financing US activities.

This panel will include:

• A discussion of the interplay with the portfolio debt rules and options.
• Convertible debt.
• Contingent debt instruments.
• Focus on income tax treaties and the conduit financing regulations
• The use of hybrid instruments and hybrid entities in inbound tax planning.

This panel will address the basics of the Freedom of Information Act (FOIA) and how to leverage the FOIA in your tax practice. Dan will cover both theory and practice to equip you to use the FOIA strategically.

This presentation will cover a variety of unique US-International tax & business considerations that apply to athletes and entertainers, whom are structuring endorsement deals, entering into transactions, or engaging in other business ventures. This presentation will also touch on a number of important business law considerations in representing such clients.

The presentation will explore cutting-edge “inbound” tax planning developments, including recent U.S. statutory, regulatory, administrative, and judicial developments. This session also will address significant U.S. Tax Court and federal court decisions addressing inbound and compliance issues as well as important foreign case law developments, recent IRS and U.S. Department of Justice initiatives, and recent Foreign Bank Account Report (FBAR) litigation developments.

The use of foreign trusts and entities can create an opportunity for US taxpayers to accumulate income free of current US taxation. To prevent such tax deferral, a complex series of rules applies to US owners of foreign entities. Rules that are even more complicated, and in some cases insufficiently developed, apply attribution rules to US beneficiaries of foreign trusts that hold foreign entities.

This session:

• Seeks to make sense of these rules.
• Signal traps for the unwary.
• Provide structuring alternatives to advise US clients who find themselves subject to anti-deferral regimes as beneficiaries of foreign trusts.

This presentation will provide a summary of the most relevant international tax compliance topics from calendar year 2024.  The discussion will include how to avoid making common errors and preparation considerations as well as suggested best practices. The topics will range across both resident and nonresident considerations and include nonresident income tax reporting on Form 1040NR including Schedule K-3, Part XIII, FIRPTA, Rental Income/Net Election, Exempt Individuals, and Foreign Partner reporting issues.  Lastly, the discussion will focus on issues with international informational reports including but not limited to Forms 5471, 926, 8992, 5472 (including the Foreign Owned US Disregarded Entity Filing), 8865, Schedules K-2/K-3, 8621, 3520/3520-A (including Foreign Pension, Foreign Grantor/Non-Grantor Trust reporting and the recent IRS Proposed Regulations Foreign Trusts), 8833 (including a discussion of the recent Net Investment Income Tax Treaty cases and treaty-tie breaker issues), 8854 (including issues related to the APA and Supreme Court Loper Bright case), 8938 (including the new IRS matching initiative from Foreign Financial Institutions under Form 8966), FinCEN BOI, and FinCEN Form 114 (FBAR).