State Taxation of Income from Foreign Affiliates PDF
Preview State Taxation of Income from Foreign Affiliates
Presenting a live 110-minute teleconference with interactive Q&A State Taxation of Income from Foreign Affiliates Multi-State Trends in Treatment of Sect. 78 Amounts, Subpart F Income, Combined Reporting and Other Items THURSDAY, MARCH 21, 2013 1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific Today’s faculty features: John Barrie, Partner, Bryan Cave, New York Richard Call, Attorney, Morrison & Foerster, New York For this program, attendees must listen to the audio over the telephone. Please refer to the instructions emailed to the registrant for the dial-in information. Attendees can still view the presentation slides online. If you have any questions, please contact Customer Service at 1-800-926-7926 ext. 10. Sound Quality Call in on the telephone by dialing 1-866-873-1442 and enter your PIN when prompted. If you have any difficulties during the call, press *0 for assistance. You may also send us a chat or e-mail [email protected] immediately so we can address the problem. Viewing Quality To maximize your screen, press the F11 key on your keyboard. To exit full screen, press the F11 key again. FOR LIVE EVENT ONLY Attendees must stay on the line throughout the program, including the Q & A session, in order to qualify for full continuing education credits. Strafford is required to monitor attendance. Record verification codes presented throughout the seminar. If you have not printed out the “Official Record of Attendance,” please print it now (see “Handouts” tab in “Conference Materials” box on left-hand side of your computer screen). To earn Continuing Education credits, you must write down the verification codes in the corresponding spaces found on the Official Record of Attendance form. Please refer to the instructions emailed to the registrant for additional information. If you have any questions, please contact Customer Service at 1-800-926-7926 ext. 10. If you have not printed the conference materials for this program, please complete the following steps: • Click on the + sign next to “Conference Materials” in the middle of the left- hand column on your screen. • Click on the tab labeled “Handouts” that appears, and there you will see a PDF of the slides and the Official Record of Attendance for today's program. • Double-click on the PDF and a separate page will open. • Print the slides by clicking on the printer icon. State Taxation of Income From Foreign Affiliates Seminar March 21, 2013 John Barrie, Bryan Cave Richard Call, Morrison & Foerster [email protected] [email protected] Today’s Program Overview Of Basic Concepts Slide 8 – Slide 28 [John Barrie] Treatment Of Dividends Slide 29 – Slide 39 [Richard Call] Handling Of Subpart F Income Slide 40 – Slide 47 [Richard Call and John Barrie] Transfer Pricing Issues Slide 48 – Slide 54 [John Barrie] Worldwide And Water's Edge Treatment Slide 55 – Slide 64 [Richard Call] Notice ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY THE SPEAKERS’ FIRMS TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN. You (and your employees, representatives, or agents) may disclose to any and all persons, without limitation, the tax treatment or tax structure, or both, of any transaction described in the associated materials we provide to you, including, but not limited to, any tax opinions, memoranda, or other tax analyses contained in those materials. The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser. 7 John Barrie, Bryan Cave OVERVIEW OF BASIC CONCEPTS State Tax Considerations Net income from the interstate operations of a foreign corporation may be subjected to state taxation, provided the levy is not discriminatory and is properly apportioned to local activities within the taxing state. 9 State Tax Considerations (Cont.) • Basics: – Nexus – Foreign Commerce Clause – P.L. 86-272 – Sourcing issues – Treaties – need specific provision 10
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