Advanced International Tax Forum
ATLAS presents a two-day technical session on handling complex tax issues. The changes in U.S. and foreign laws, recent court decisions and tax rulings (both published and private) can have a major impact on the tax cost of - and the most advantageous approach to - doing business abroad. This session will focus on tax planning strategies, which will be used to reduce your company’s worldwide tax rate.
Current Tax Developments With International Cost Sharing Arrangements
ATLAS' two-day extensive technical review with live instruction will be involved with all aspects of international tax related cost sharing arrangements such as, formation, operation, documentation, reporting, and other related matters. In just the last few months, very important issues have been raised which must be examined before one should enter into a cost sharing arrangement or continue to operate an existing arrangement.
Current Tax Issues in the High Tech Industries
ATLAS has created this new seminar to address the hottest tax and accounting topics facing high tech industry. Over the last year, very significant changes have occurred in the tax area. Hear from the industry leaders and IRS specialists on how the final cost sharing regulations and proposed service regulations will impact the industry, as well as the planning opportunities embedded in these regulations.
Earnings & Profits of Foreign Subsidiaries
ATLAS' two-day seminar will discuss such topical subjects as determination of earnings and profits and elections, reducing foreign taxes, E&P rules affecting the determination of Subpart F income and repatriation planning. The new IRS proposed regulations contain a number of important rules dealing with earnings & profits, Subpart F income and foreign tax credits, many companies have to take a new look at their foreign subsidiaries¹ earnings and profits and are finding they have to re-examine this aspect of tax planning.
Foreign Tax Credit Planning
ATLAS presents a two-day seminar on maximizing foreign tax credit benefits and implementing the latest strategies for minimizing the U.S. tax cost on reinvesting or repatriating foreign earnings in today's unstable economic markets. With the decline of corporate tax rates around the world, tax practitioners today need to be aware of the latest strategies for reducing foreign taxes, as well as techniques for maximizing the foreign tax credit limitation formula.
Global Executive Compensation Forum
ATLAS is pleased to announce a NEW seminar dealing with worldwide executive compensation. This session will emphasise the latest issues facing U.S. companies programs including termination, pensions, stock options benefits taxes both for present and retired employees. It will also discuss performance based on pay & global equity compensation & innovative tax planning approaches to name a few.
Handling IRS Audits
This seminar will cover IRS objectives starting from initial contact to resolving tax disputes, as well as the new current audit program that allows for an audit in that actual year. ATLAS has assembled key IRS personnel to address the overall concepts of their new audit program, the memorandum of understanding, and your obligation to assist in the timely completion of the audit.
Hot Issues in Corporate Tax
This seminar is designed to cover general domestic corporate tax developments. Issues of interest to corporate tax directors and others involved in directing corporate tax functions will be covered at the program. Issues such as domestic corporate changes under the 2005 Tax Act, including consolidated returns, research and development and mergers and acquisitions and other key topics will be addressed.
Hot Issues in International Tax
ATLAS invites you to a seminar on the most relevant U.S. tax issues in cross-border tax planning from a corporate perspective. Learn about the hottest U.S. issues including the American Jobs Creation Act and the Treasury Department's ongoing efforts to issue regulatory guidance on a variety of international issues from our experienced faculty who will guide you through the maze of recent IRS regulations and reporting requirements and show you practical solutions for reducing foreign and U.S. taxes at your company.
Intermediate U.S. International Tax Update
ATLAS introduces a two and a half day seminar on the latest planning ideas in U.S. international taxation for intermediate level practitioners. New topics offered only by ATLAS have been added to improve and update our 2008 sessions. Let our experienced faculty explain and guide you through the maze of U.S. international tax provisions using examples and case studies.
Intermediate Taxation of Financial Products & Derivations
ATLAS has assembled the leading tax professionals to chair and speak at this session. This session will cover the latest developments for corporate finance executive, financial institutions and institutional investor who use, market or invest in financial products & derivatives. Focus of this session is more intense and is backed up by a series of case studies to give attendees a more detailed understanding of the many complex issues in dealing with financial products. It will address crucial tax and accounting issues including IRS and FAS pronouncements and recent developments in practical utilization of these products.
Introduction to U.S. International Tax
ATLAS is pleased to offer its U.S. international tax course for beginners. Learn the A-B-C's of U.S. international taxation, so you can advise your management or client on the pitfalls and opportunities of operating overseas. In addition, obtain valuable job skills that will enable you to recognize key issues in global tax planning and make contacts with our faculty of experienced tax professionals, who can facilitate your research and assist you in understanding the U.S. tax effects of generating income or losses from operations overseas.
Introduction to Securitization Transactions
ATLAS is delighted to offer this two-day comprehensive introductory program on securitization. Over the course of two days, delegates will develop a keen understanding of the key considerations necessary to structure and manage securitization transactions. The course also offers updates on the latest bank regulatory issues, bankruptcy considerations, accounting and tax issues, and case studies of recent securitization transactions.
Introduction to Taxation of Financial Products & Derivatives
ATLAS presents a two-day introductory seminar that will discuss the latest developments for corporate finance executives, financial institutions and institutional investors who use, market or invest in financial products and derivatives. Over the last few years financial products and derivatives have become a mainstay in the financial markets. Corporations and financial institutions are using these products to hedge risks or gain certain financial or economic benefits. A detailed understanding of what these products are and the relevant tax and accounting issues is critical to ensure that all parties to the transaction achieve the desired results.
Introduction to Tax Issues Involving of Mergers & Acquisitions
ATLAS presents a two-day introductory level seminar for corporate tax and non-tax executives involved in U.S. and cross-border mergers and acquisitions. Understand the key legal and tax negotiating points from the perspective of the buyer and seller; what key legal and tax concerns you need to find out in conducting due diligence and the latest IRS developments affecting companies involved in tax-free transactions and the deduction of transaction costs.
Legal, Tax & Financial Aspects of Captive Insurance Companies
A two- day conference on understanding the key tax and legal issues needed to maximize benefits in utilizing a captive insurance subsidiary. The captive insurance industry is thriving in today's harden insurance markets due to lower costs of insurance premiums to corporations and high net worth individuals. This session has been updated to provide you and your company with the latest and most effective cost saving opportunities available in today's insurance market. This session will address how effective utilization of an insurance affiliate offers major tax and non-tax advantages.
Symposium on International Transfer Pricing
This two-day technical seminar will feature specific pricing topics that include corporations worldwide effective tax rate, that latest intellectual property developments, establishing the best method for sales to a distribution, advanced pricing agreements and determining the cost of transferring intangibles offshore. This seminar will also focus on specific industry related issues as well as transfer pricing pertaining to various countries.
Tax Aspects of Cross-Border Acquisitions & Reorganizations
ATLAS has assembled some of the leading legal, tax and financial consultants to provide you with the practical, in-depth knowledge you need to implement your acquisition strategy. Virtually every corporate restructuring or acquisition of any significant size involves issues of international taxation and many of the rules have changed significantly in the last few years. This seminar will provide an in-depth analysis of these and other issues.
Taxation of Intellectual Property
The objective of this ATLAS conference is to discuss, analyze and provide examples of various types of tax issues pertaining to intellectual property and tax related provisions encountered in licensing and major business agreements relating to intellectual property assets. It is important that your company or clients have a clear strategy for managing the tax issues and consequences relating to your intellectual property assets.
Tax Planning Summit for Key Latin American Countries
ATLAS has assembled, for this year’s Summit, a group of leading U.S. and foreign experts on the tax laws in Latin America, including tax executives with extensive Latin American experience in leading U.S. multinationals. Together they will provide a systematic and comprehensive treatment of the tax systems of these countries as they affect U.S. companies and their foreign affiliates.
Tax Planning In Asia
ATLAS is please to announce a new seminar on tax planning in selected countries. This seminar has a dual purpose, to service as a source of new tax ideas and techniques, as well as, a forum to learn about rapidly developing and changing tax rules. This program will focus on keeping abreast of tax changes and tax-planning techniques in selected Asian countries including the People’s Republic of China. It will deal with the issues faced by U.S. Multinationals with investments and operations in those areas
Tax Planning for CFCs Under Subpart F
ATLAS is pleased to announce a two-day technical and planning seminar on the latest issues affecting the operations of CFC's. New IRS regulations and case law are constantly increasing the cost of CFC compliance for the corporate tax departments. Learn how you can help your company or client ease their compliance burden with respect to operating results of a CFC.
Tax Aspects of Intercompany Pricing
ATLAS presents a two-day technical seminar for intermediate to advanced level practitioners on the latest transfer pricing strategies being utilized by companies today. Technical sessions will examine the most popular pricing methods being applied by the IRS on audits on intercompany sales and how taxpayers are using economists and Transfer Pricing Study to defend against IRS.
Tax Issues Relating to Research & Development
ATLAS' two-day seminar on what qualifies as research & development expenses is important for both domestic & international tax purposes. In this seminar the speakers will discuss current issues being raised by the Internal Revenue Service with respect to interrelationships of research & development in both domestic & international areas.
Transfer Pricing Issues Regarding Manufacturing in Puerto Rico
ATLAS presents a two-day seminar that will address transfer Pricing strategies for manufacturing and doing business in Puerto Rico. We will also address current developments, pending developments, and planning in the context of the Sec. 936 rules and the aftermath will be discussed.
Tax Treaties: Recent Developments & Emerging Issues
ATLAS’ new two-day income tax treaty seminar is especially timely given the recent increase in the speed and significance of U.S. income tax treaty developments. New treaties and major protocols with the Netherlands, Japan, the U.K., Australia, Mexico and Barbados, for example, incorporate significant departures from earlier U.S. treaties. Tax treaties are a pervasive aspect of international taxation -- the overwhelming majority of all cross-border commercial transactions involve foreign jurisdictions where a bilateral U.S. income tax treaty is potentially applicable.
U.S. Tax Allocations & Apportionment of Expenses including U.S. Production Deduction
Over the last few years, the source of income and allocations of expense area of U.S. international taxation has become ever increasingly complex. Even experienced corporate, accounting and legal tax professionals are hard pressed to keep up. ATLAS' two-day technical seminar will address these complex rules for apportioning U.S. expenses to foreign source income and focuses on strategies for maximizing the foreign tax credit limitations formula. This session is specifically designed to present comprehensive analysis of a wide variety of complex corporate tax issues relating to the 1.861 regulations and analyzes the Sec. 864(e) from varied perspectives.
U.S. Tax Aspects of International Shipping
ATLAS has assembled leading tax specialists from around the U.S. to address the effects of the American Jobs Creation Act on the shipping industry, including the repeal of foreign base company shipping income provisions and enactment of the new tonnage tax. We have included a panel of government officials to discuss recent regulations, rulings, IRS examination procedures and other hot tax issues relating to the shipping industry. Our distinguished panel of speakers will also cover tax issues relating to income tax treaties, transfer pricing, Section 883, source of shipping income, subpart F, and IRS examination issues, to name a few.