Speaking Engagements

Speaking Engagements

Estate Planning Issues for Foreign Investors in U.S. Real Estate and Businesses: Tax Treaties, Corporate Structures

This CLE/CPE webinar will provide estate planners with a helpful guide to estate planning challenges and opportunities for foreign investors holding U.S. real estate and business interests. The panel will discuss the tax rules and treaty provisions impacting estate planning associated with nonresident investors. The panel will focus on strategies to minimize gift and estate tax taxation of real estate and business interests–whether held individually or through an entity–for counsel and advisers working with nonresident investors.

Tuesday, August 16, 2022 (in 11 days)

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Navigating Estate and Gift Tax Treaties, U.S. Situs Assets, and Allowable Deductions

This CLE/CPE webinar will provide trusts and estate attorneys with an in-depth discussion on interpreting estate and gift tax treaties and related challenges for certain assets and available deductions. The panel will discuss the application of U.S. tax laws to assets owned by green card holders and nonresidents, reporting requirements, Form 706-NA, assets included in the gross estate, available deductions, and the effect of death tax treaties on the taxable estate.

Tuesday, August 30, 2022

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Form 5471 Attribution Rules: New Categories of Filers and Rev Proc 2019-40 Safe Harbors

This course will explain the attribution rules for stock ownership for individuals and entities and the filing requirements of Form 5471. Our panel of international tax experts will discuss determining direct and indirect stock ownership that can result in unexpected filing obligations.

Tuesday, September 27, 2022

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Extracting, Preserving, and Authenticating Digital Evidence: What’s discoverable, how to obtain, and more

The purpose of this class is to educate claims professionals on how digital evidence is extracted from cell phones, computers, and other electronic devices.

Live Video-Broadcast: August 19, 2022EST: 12:00 – 2:10 PMCST: 11:00 – 1:10 PMMST: 10:00 – 12:10 PMPST: 09:00 – 11:10 AM

Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits

This course will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the requirements of these detailed schedules, including the most recent changes made to these schedules.


29th Annual Estate Planning Symposium

Estate Planning & Probate Section is sponsoring
29th Annual Estate Planning Symposium (Back in Person at the Lesher)
Tuesday, May 17, 1:00PM – 5:45PM

IRC Section 367 Outbound Transfers of Assets: Identifying Transactions, Reporting Requirements and Exception
December 1, 2021 • CPE • Live Webinar with Q&A

This webinar will discuss the U.S. tax consequences of outbound asset transfers to foreign corporations. Our panel of international tax experts will explain the interplay of Section 367 with the nonrecognition rules, reporting responsibilities, and gain recognition agreements (GRAs) with the IRS for taxpayers who have made or are contemplating overseas transfers of …. READ MORE

Foreign Tax Credit Limitations Under Section 904: IRS Regulations and Guidance for Tax Counsel
September 21, 2021 • CLE/CPE • Video Webinar with Q&A

This CLE/CPE course will provide tax counsel with a critical analysis of IRS foreign tax credit (FTC) limitations under Section 904. The panel will discuss key provisions of the regulations, additional “buckets” of foreign income grouping, allocation and apportionment rules, limitations under Section 904(b)(4), carryover and carryback rules under Section 904(c), and transition tax impl….READ MORE

Form 5471 Attribution Rules: New Categories of Filers & Rev Proc 2019-40 Safe Harbors
August 11, 2021 • CPE, EA • Live Webinar

This webinar will explain the attribution rules for stock ownership for individuals and entities and the related filing requirements of Form 5471. Our panel of international tax experts will discuss the determination of direct and indirect stock ownership that can result in unexpected filing obligat… READ MORE

Form 5471 Attribution Rules: New Categories of Filers & Rev Proc 2019-40 Safe Harbors
August 11, 2021 • CPE, EA • Live Webinar

This webinar will explain the attribution rules for stock ownership for individuals and entities and the related filing requirements of Form 5471. Our panel of international tax experts will discuss the determination of direct and indirect stock ownership that can result in unexpected filing obligat… READ MORE

Form 5471: Preparing Schedule C Income Statement and Schedule F Balance Sheet
Overcoming Challenges With Functional Currency, U.S. GAAP Presentation, and Translation Ad…
August 5, 2021 • CPE, EA • Live Webinar

This webinar will provide practical steps for meeting the requirements of Form 5471 Schedules C and F, the income statement, and balance sheet for tax preparers. Our panel will provide insights into meeting the IRS requirements for including these statements, including reporting these in functional… READ MORE

Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits
August 31, 2021 • CPE, EA • Webinar

This webinar will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the preparation of these detailed schedules after the multitude of changes made by recent tax reform. Description Properly preparing Form 5471, Information Return of U.S… READ MOREForm 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits
June 22, 2021 • CPE, EA • CPE On-Demand, Download

This webinar will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the preparation of these detailed schedules after the multitude of changes made by recent tax reform. Description Properly preparing Form 5471, Information Return of U.S… READ MOREForm 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abateme…
Establishing Reasonable Cause Exceptions, Appeals Prior to Payment, Collection Due Process…
May 20, 2021 • CLE, CPE, EA • CLE On-Demand, Download

This CLE/CPE webinar will provide tax counsel with a comprehensive and practical guide to a deep exploration into the reporting regime for U.S. taxpayers’ ownership of foreign trust assets on IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts… READ MOREU.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulati…
Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Pro…
March 25, 2021 • CLE, CPE, EA • CLE On-Demand, Download

This CLE/CPE webinar will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e). Description The 2017 tax reform provided new… READ MOREForm 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporation: Line-by-Line
Deep Dive Into Additional Categories, Classifications, and Sections of Complex Schedule J
November 12, 2020 • CPE, EA • CPE On-Demand, Download

This webinar will provide tax advisers with a practical, in-depth guide to completing Form 5471’s recently revised Schedule J, Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporations. The panel will take a line-by-line approach to the form, discussing each of the income items listed… READ MOREForm 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporation: Line-by-Line
Deep Dive Into New Categories, Classifications, and Sections of Complex Schedule J
November 5, 2019 • CPE, EA • CPE On-Demand, Download

This webinar will provide tax advisers with a practical, in-depth guide to completing Form 5471’s newly revised Schedule J, Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporations. The panel will take a line-by-line approach to the form, discussing each of the income items listed in… READ MOREAdvanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act In…
July 26, 2017 • CLE, CPE, EA • CLE On-Demand, Download

This webinar will provide tax counsel and advisers with a thorough and practical guide to strategies for administrative challenges and defenses against penalty assessments for FBAR violations. The panel will contrast the penalty structures between FBAR and other foreign-related information filings a… READ MORE

415.318.3990