{"id":3917,"date":"2021-07-12T20:26:15","date_gmt":"2021-07-12T20:26:15","guid":{"rendered":"https:\/\/sftaxcounsel.com\/?page_id=3917"},"modified":"2024-01-29T03:20:25","modified_gmt":"2024-01-29T03:20:25","slug":"speaking-engagements","status":"publish","type":"page","link":"https:\/\/sftaxcounsel.com\/speaking-engagements\/","title":{"rendered":"Speaking Engagements"},"content":{"rendered":"\n

International Tax Virtual Conference 2024<\/a><\/p>\n\n\n\n

Globalization impacts the work of businesses and individuals and the tax professionals who advise them. If your clients are facing issues because they have international holdings, are U.S. citizens working in foreign countries or are foreign nationals. As a tax professional, you need an understanding of the forms, reporting requirements, standards and regulations required for international tax. Clear overviews, insightful discussions and best practices from international tax experts are the hallmarks of this event.<\/p>\n\n\n\n

Date:<\/strong> Jan. 31, 2024<\/p>\n\n\n\n

Time:<\/strong> 8:30 a.m. \u2013 4 p.m. PT<\/p>\n\n\n\n

CPE:<\/strong> 8<\/p>\n\n\n\n

Real Estate Holding Structures for Foreign Investors: Income and Estate Tax Implications of U.S. and Foreign Entities<\/a><\/p>\n\n\n\n

This webinar will point out the importance of selecting an appropriate holding structure for U.S. real estate owned by foreign taxpayers. Our panel of veteran international tax authorities will weigh the benefits and caveats of choosing a foreign or U.S. entity, including partnerships, corporations, and trusts, as well as analyze the income and estate tax implications of these alternatives.<\/p>\n\n\n\n

Thursday, February 22, 2024<\/p>\n\n\n\n

1:00pm-2:50pm EST, 10:00am-11:50am PST<\/em><\/p>\n\n\n\n

Early Registration Discount Deadline, Friday, February 2, 2024<\/p>\n\n\n\n

Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits<\/a><\/p>\n\n\n\n

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.<\/p>\n\n\n\n

Conducted on Wednesday, December 20, 2023<\/p>\n\n\n\n

Recorded event now available<\/p>\n\n\n\n

Foreign Cloud Computing Transactions: U.S. Taxation of Service, Intangible, Copyright, and Royalty Income<\/a><\/p>\n\n\n\n

This webinar will discuss U.S. taxation of foreign computer programs and cloud computing transactions. Our panel of international tax attorneys will explain U.S. sourcing rules for overseas digital commerce and the latest regulations relating to taxation and classification of computer-related business activity.<\/p>\n\n\n\n

Tuesday, October 24, 2023 (in 6 days)<\/em><\/p>\n\n\n\n

1:00pm-2:50pm EDT, 10:00am-11:50am PDT<\/em><\/p>\n\n\n\n

Form 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abatements for Delinquencies<\/a><\/p>\n\n\n\n

This CLE\/CPE course 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. The panel will detail the events and transactions that require reporting and discuss tax counsel’s role in remedying an absent or incorrect filing, including navigating the penalty abatement process for failure to correctly and timely file a Form 3520.<\/p>\n\n\n\n

Thursday, October 19. 2023<\/p>\n\n\n\n

1:00pm-2:30pm EDT, 10:00am-11:30am PDT<\/em><\/p>\n\n\n\n

FIRPTA: New Proposed Regulations, Identifying Exempt DCQIEs, Withholding Rules, Holding Structures<\/a><\/p>\n\n\n\n

This webinar will analyze FIRPTA (Foreign Investment in Real Property Tax Act) rules for foreign investors in U.S. real estate. Our panel of multinational tax experts will review the recently released regulations, consider appropriate holding structures to minimize U.S. tax liability, and detail the withholding tax remittance requirements for non-citizens and tax professionals working with nonresident taxpayers. <\/p>\n\n\n\n

Tuesday, June 6, 2023<\/p>\n\n\n\n

1:00pm-2:50pm EDT, 10:00am-11:50am PDT<\/em><\/p>\n\n\n\n

Early Registration Discount Deadline, Friday, May 12, 2023<\/p>\n\n\n\n

Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporations: Line-by-Line<\/a><\/p>\n\n\n\n

This course 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 in the various sub-sections of IRC 959, and detail how to identify the Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income required in Part II. This is an advanced level webinar for attendees well versed in prior revisions of Form 5471. <\/p>\n\n\n\n

Tuesday, April 25, 2023<\/p>\n\n\n\n

1:00pm-2:50pm EDT, 10:00am-11:50am PDT<\/em><\/p>\n\n\n\n

U.S. Estate and Gift Tax Treaties: Utilizing Specific Provisions to Mitigate Inheritance Taxes<\/a><\/p>\n\n\n\n

This webinar will review standard provisions in U.S. estate and gift tax treaties and explore specific provisions in treaties with particular countries that can be utilized to reduce or eliminate exposure to U.S. transfer taxes. <\/p>\n\n\n\n

Wednesday, March 8, 2023<\/p>\n\n\n\n

1:00pm-2:50pm EST, 10:00am-11:50am PST<\/em><\/p>\n\n\n\n

Early Registration Discount Deadline, Friday, February 10, 2023<\/p>\n\n\n\n

U.S. Tax Planning for Foreign Nationals: Sourcing of Income, Exemptions, Tax Treaties, and Pitfalls to Avoid<\/a><\/p>\n\n\n\n

This CLE\/CPE course will provide tax professionals guidance on key U.S. tax planning strategies available to foreign nationals and pitfalls to avoid. The panel will discuss key considerations for resident and nonresident aliens for U.S. tax purposes, sourcing of income and challenges that disrupt tax planning, available exemptions and the use of tax treaties, and U.S. tax planning tips for foreign nationals. <\/p>\n\n\n\n

Tuesday, November 29, 2022 (<\/em><\/p>\n\n\n\n

1:00pm-2:30pm EST, 10:00am-11:30am PST<\/em><\/p>\n\n\n\n

International Tax Conference<\/a><\/p>\n\n\n\n

Grab your passports, and take a trip to our TaxTrek International Virtual Conference! Globalization isn\u2019t just a buzzword describing our modern economy\u2014it impacts the work of businesses and individuals and the tax professionals who advise them. Whether your clients are individuals with international holdings, U.S. citizens working in foreign countries, multinational families, families with international business interests or foreign nationals working in the U.S., you need an understanding of the forms, reporting requirements, standards and regulations required for international tax. Clear overviews, insightful discussions and best practices from international tax experts are the hallmarks of this event. <\/p>\n\n\n\n

Monday, December 5th Virtual<\/p>\n\n\n\n

Estate Planning Issues for Foreign Investors in U.S. Real Estate and Businesses: Tax Treaties, Corporate Structures<\/a><\/p>\n\n\n\n

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. <\/p>\n\n\n\n

Tuesday, August 16, 2022 (in 11 days)<\/em><\/p>\n\n\n\n

1:00pm-2:30pm EDT, 10:00am-11:30am PDT<\/em><\/p>\n\n\n\n

Navigating Estate and Gift Tax Treaties, U.S. Situs Assets, and Allowable Deductions<\/a><\/p>\n\n\n\n

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. <\/p>\n\n\n\n

Tuesday, August 30, 2022<\/p>\n\n\n\n

1:00pm-2:30pm EDT, 10:00am-11:30am PDT<\/em><\/p>\n\n\n\n

Form 5471 Attribution Rules: New Categories of Filers and Rev Proc 2019-40 Safe Harbors<\/a><\/p>\n\n\n\n

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. <\/p>\n\n\n\n

Tuesday, September 27, 2022<\/p>\n\n\n\n

1:00pm-2:50pm EDT, 10:00am-11:50am PDT<\/em><\/p>\n\n\n\n

Extracting, Preserving, and Authenticating Digital Evidence: What\u2019s discoverable, how to obtain, and more<\/a><\/p>\n\n\n\n

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

Live Video-Broadcast: August 19, 2022<\/strong>EST: 12:00 – 2:10 PMCST: 11:00 – 1:10 PMMST: 10:00 – 12:10 PMPST: 09:00 – 11:10 AM<\/strong><\/p>\n\n\n\n

Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits<\/a><\/p>\n\n\n\n

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. <\/p>\n\n\n\n


29th Annual Estate Planning Symposium <\/a><\/p>\n\n\n\n

\n\nEstate Planning & Probate Section is sponsoring
29th Annual Estate Planning Symposium (Back in Person at the Lesher)<\/strong>
Tuesday, May 17, 1:00PM – 5:45PM\n\n<\/p>\n\n\n\n

IRC Section 367 Outbound Transfers of Assets: Identifying Transactions, Reporting Requirements and Exception<\/a>
December 1, 2021 \u2022 CPE \u2022 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<\/a> <\/p>\n\n\n\n

Foreign Tax Credit Limitations Under Section 904: IRS Regulations and Guidance for Tax Counsel<\/a>
September 21, 2021 \u2022 CLE\/CPE \u2022 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<\/a>
<\/p>\n\n\n\n

Form 5471 Attribution Rules: New Categories of Filers & Rev Proc 2019-40 Safe Harbors<\/a>
August 11, 2021 \u2022 CPE, EA \u2022 Live Webinar<\/p>\n\n\n\n

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<\/a><\/p>\n\n\n\n

Form 5471 Attribution Rules: New Categories of Filers & Rev Proc 2019-40 Safe Harbors<\/a>
August 11, 2021 \u2022 CPE, EA \u2022 Live Webinar<\/p>\n\n\n\n

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<\/a><\/p>\n\n\n\n

Form 5471: Preparing Schedule C Income Statement and Schedule F Balance Sheet<\/a>
Overcoming Challenges With Functional Currency, U.S. GAAP Presentation, and Translation Ad…<\/em>
August 5, 2021 \u2022 CPE, EA \u2022 Live Webinar<\/p>\n\n\n\n

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<\/a><\/p>\n\n\n\n

Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits<\/a>
August 31, 2021 \u2022 CPE, EA \u2022 Webinar<\/p>\n\n\n\n

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 MORE<\/a>Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits<\/a>
June 22, 2021 \u2022 CPE, EA \u2022 CPE On-Demand, Download<\/p>\n\n\n\n

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 MORE<\/a>Form 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abateme…<\/a>
Establishing Reasonable Cause Exceptions, Appeals Prior to Payment, Collection Due Process…<\/em>
May 20, 2021 \u2022 CLE, CPE, EA \u2022 CLE On-Demand, Download<\/p>\n\n\n\n

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 MORE<\/a>U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulati…<\/a>
Navigating the Mismatches of U.S. and Foreign Tax Law, Key Planning Techniques for Tax Pro…<\/em>
March 25, 2021 \u2022 CLE, CPE, EA \u2022 CLE On-Demand, Download<\/p>\n\n\n\n

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 MORE<\/a>Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporation: Line-by-Line<\/a>
Deep Dive Into Additional Categories, Classifications, and Sections of Complex Schedule J<\/em>
November 12, 2020 \u2022 CPE, EA \u2022 CPE On-Demand, Download<\/p>\n\n\n\n

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 MORE<\/a>Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporation: Line-by-Line<\/a>
Deep Dive Into New Categories, Classifications, and Sections of Complex Schedule J<\/em>
November 5, 2019 \u2022 CPE, EA \u2022 CPE On-Demand, Download<\/p>\n\n\n\n

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 MORE<\/a>Advanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act In…<\/a>
July 26, 2017 \u2022 CLE, CPE, EA \u2022 CLE On-Demand, Download<\/p>\n\n\n\n

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<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

International Tax Virtual Conference 2024 Globalization impacts the work of businesses and individuals and the tax professionals who advise them. If your clients are facing issues because they have international holdings, are U.S. citizens working in foreign countries or are foreign nationals. As a tax professional, you need an understanding of the forms, reporting requirements, […]<\/p>\n","protected":false},"author":7,"featured_media":3918,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"templates\/secondary-template.php","meta":{"_monsterinsights_skip_tracking":false,"_monsterinsights_sitenote_active":false,"_monsterinsights_sitenote_note":"","_monsterinsights_sitenote_category":0,"footnotes":""},"_links":{"self":[{"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/pages\/3917"}],"collection":[{"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/users\/7"}],"replies":[{"embeddable":true,"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/comments?post=3917"}],"version-history":[{"count":18,"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/pages\/3917\/revisions"}],"predecessor-version":[{"id":5389,"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/pages\/3917\/revisions\/5389"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/media\/3918"}],"wp:attachment":[{"href":"https:\/\/sftaxcounsel.com\/wp-json\/wp\/v2\/media?parent=3917"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}