Understanding IRS

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The Treasury and the IRS are in the process of finalizing the laws concerning contract manufacturing arrangements as per the anti-deferral regime Subpart F. Set to take effect for tax years of foreign controlled companies beginning after June 30th, 2009, the new guidance aims to update and modernize the contract manufacturing regs under Subpart F. While the Regs are generally well received by tax payers, there is much confusion surrounding key areas such as: retention of the fundamental approach, clarification of personal property sale issues, and turnkey CFC’s to name a few.

A panel of key thought leaders and contract manufacturing experts will discuss the final guidance and its impact on your firm. Understanding the IRS New Contract Manufacturing Rules LIVE Webcast is a must attend webcast for companies who utilize contract manufacturing arrangements seeking to understand the fundamentals of and how it may apply to their company.

Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Group, LLC
Recommended CLE/CPE Hours: 1.75 - 2.0
Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.
Advance Preparation: Print and review course materials
Course Code: 093887
Recording Fee: $299 (Please click here for details)
NASBA Sponsor Number: 109004

 

Featured Speakers for Understanding the IRS live webcast:


Proposed Agenda (click here to view more)
SEGMENT 1:


Ethan Atticks, Senior Technical Reviewer of Branch 2, Office of the Associate Chief Counsel (International),
Internal Revenue Service

** Speaker Talking Points to be added soon.. **

SEGMENT 2:


William P. Elliott, CPA,. ABV/CVA, J.D.,LL.M., Partner and Firm Director of International Tax,
Cherry, Bekaert & Holland, L.L.P.

- Effect of New Contract Manufacturing Regulations on Supply Chain Structures
    - U.S. Treatment of Import and Contract Processing Arrangements Under Contract Mfg. Prop. Regs.
    - Adjusting Foreign (non-U.S.) Contract Mfg. Structures for New Rules
    - “Turnkey” manufacturing and ODM arrangements.
    - Automated manufacturing
    - Unrelated-to-unrelated structures.

SEGMENT 3:


Carol P. Tello, Partner, (Former Special Assistant to the Assistant Commissioner (International), Internal Revenue Service),
Sutherland Asbill & Brennan LLP

- Dealing with the branch rules
- Planning for repeal of international check-the-box
- Impact of OECD Business Restructurings Draft Report

SEGMENT 4:


H. David Rosenbloom, Member, (Former International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of Treasury),
Caplin & Drysdale

- Relationship of the contract manufacturing rules and the branch rule
- Subtleties of the "substantial contribution" factors
- Rejection of the "Its" defense
- Missing definition of a "branch"
- The multiple manufacturing location rules
- Tax rate disparity test
- Calculation of tainted branch income



Internal Revenue Service
Ethan Atticks
Senior Technical Reviewer of Branch 2, Office of the Associate Chief Counsel (International)
                       speaker bio »»

Cherry, Bekaert & Holland, L.L.P.
William P. Elliott, CPA,. ABV/CVA, J.D.,LL.M.
Partner and Firm Director of International Tax
speaker bio »»

Sutherland Asbill & Brennan LLP
Carol P. Tello
Partner,(Former Special Assistant
to the Assistant Commissioner (International), Internal Revenue Service)
                       speaker bio »»

Caplin & Drysdale
H. David Rosenbloom
Member, (Former International Tax Counsel and Director,
Office of International Tax Affairs, U.S. Department of Treasury)
                       speaker bio »»

Who Should Attend?

- Manufacturing Attorneys
- Contract Manufacturing Experts
- International Tax Counsel and Directors
- Finance Team
- Tax Attorneys
- Senior Management

Why Attend?

This is a must attend event to everyone to hear the latest development on IRS new contract manufacturing rules
- Detailed guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A

Registration Information:                                                                                                                                    


 

 

 

 


Understanding the IRS New Contract Manufacturing Rules LIVE Webcast
Speaker Firms:


Internal Revenue Service




Sutherland Asbill & Brennan LLP






 

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Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.

Attention New York Attorneys:

This program is approved for CLE credit under New York’s Approved Jurisdiction policy. The Knowledge Group, LLC is an approved sponsor in the state of California, a New York Approved Jurisdiction. This program fulfills the non-traditional format requirement of exceeding 60 minutes in length. Please note only experienced attorneys (more than 2 years) are eligible to receive CLE credit via non-traditional format learning platforms. The Knowledge Group will verify attendance during the webcast via secret words (3 per credit hour) and by auditing attendees log in and log out records. All verification instructions will be provided during the webcast. Once attendance verification requirements have been completed, the attendee will be issued a certificate of attendance be The Knowledge Group for the course with the recommended number of credit hours. The Certificate of Attendance is normally sent via email in 24 hours or less.

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