This course begins with a brief review of recent developments in international tax law. Issues covered include: the recent October 12, 2017 outreach by Eight U.S. Senators, a similar July 2017 initiative involving 16 House Representatives, and a number of letters from prominent investors and financial analysts to the Chair of the U.S. Financial Accounting Standards Board stating their views on changes to the disclosure requirements for income tax information. These disclosures require that large companies disclose, among other things: income, assets, number of employees, and taxes paid on a country by country basis. The U.S. Senators noted that recent estimates show that U.S. companies currently hold more than $2.6 trillion offshore, with significant holdings in tax haven jurisdictions.
Country-by-country disclosure is important for policymakers and the general public, as the information will be useful in examining economic trends and addressing public policy issues. This course examines the risks and challenges associated with recent changes and trends concerning international tax disclosure requirements. Join attorney R. John Smith for this informative deep dive into international tax matters.
R. John Smith, Esq., is a tax law expert with over 30 years focus upon Partnership Tax law matters. He is author of the treatise "Practical Insights on Tax Law“, Tax Law Writer and Editor of Tax Law CPE courses; works closely with national subject matter professionals in the design and execution of complex, large-scale partnership transactions, has lectured on complexities of Subchapter K, partnership modeling Debt allocations, distributions, bringing in new partners, sales of partnership shares, terminations, US Treasury proposed partnership regulations on hot assets under Code Sec. 751(b). which mandate bookups (revaluing partnership assets at fair market value) to lock in each partner’s share of Code Sec. 751 property; nuances of joint venture structuring, US Taxation of international transactions, U.S. International Taxation,Cross-Border Transfers,taxation of outbound transfers to, as well as inbound transfer from, foreign corporations is determined under Code Sec. 367; Reorganizations,Outbound Transfers to Foreign Corporations; Acquisitive Reorganizations;Outbound Acquisitive Reorganizations;Inbound Transfers From a Foreign Corporation;Inbound Acquisitive Reorganizations; Foreign-To-Foreign Acquisitive Reorganizations; Foreign currency translations, Hedges of Foreign Currency Risk with Debt Instruments held as Capital Assets; Tax Law Strategy for tax attributes including foreign Qualified Business Unit earnings remittances, foreign corporation actual and deemed distributions, foreign income taxes etc. throughout the US, Israel, Asia etc. He is member of the U.S. Tax Court Bar and the U.S. Supreme Court Bar. Jack is an alumni of Harvard University and New York University School of Law.
As usual, Lawline provides superb substantive content from superb Instructors. - Mr. R. John Smith is the absolute best of the best!
Great demeanor and attitude of presenter, and obviously well studied.
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