tax notes international - Tuck School of Business - Dartmouth College

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February 9 U.S. International Tax Reporting and Compliance — Fort Lauderdale, Fla. The Council for International Tax Education will sponsor a two-day seminar focusing on the latest IRS tax reporting requirements for U.S. companies with foreign operations. • Tel: (914) 328-5656 • E-mail: info@citeusa.org International Tax — New York. Networking Seminars will sponsor a oneday introduction to international tax with topics including expense apportionment, earnings and profits, the foreign tax credit, and Subpart F income. • Tel: (914) 874-5395 • E-mail: elizabeth@networkingseminars.net February 10 International Tax — New York. Networking Seminars will sponsor a oneday international tax update with topics including new contract manufacturing regulations, recent changes to the foreign tax credit, new service rules under section 482, and treaty developments. • Tel: (914) 874-5395 • E-mail: elizabeth@networkingseminars.net February 11 International Tax — New York. Networking Seminars will sponsor a oneday advanced international tax seminar with topics including inbound and outbound transactions, transfers of intangible assets, permanent establishments under tax treaties, foreign exchange, and financing foreign subsidiaries. • Tel: (914) 874-5395 • E-mail: elizabeth@networkingseminars.net February 16 U.S. International Tax — Houston. ATLAS will sponsor a two-day introduction to U.S. international tax with topics including key issues involving the American Jobs Creation Act and the U.S. tax effects of generating income or losses from operations overseas. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com February 18 U.S. International Tax — Houston. ATLAS will sponsor a two-and-a-halfday intermediate-level seminar on U.S. international taxation. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com February 23 U.S. Transfer Pricing — New York. The Council for International Tax Education will sponsor a two-day intermediate- to advanced-level seminar focusing on U.S. transfer pricing issues. • Tel: (914) 328-5656 • E-mail: info@citeusa.org Tax Accounting for U.S. Multinationals — New York. The Council for International Tax Education will sponsor a two-day conference on topics including computing taxes in assembling the corporate tax provision under FAS 109, tax accounting requirements for reporting domestic production benefits, and how FIN 48 rules apply to uncertain tax positions for public and nonpublic companies. • Tel: (914) 328-5656 • E-mail: info@citeusa.org February 25 Cross-Border Tax Controversies — Washington. The Tax Council Policy Institute will hold a two-day symposium focusing on topics including dispute resolution, transfer pricing, indirect taxation, and permanent establishment and nexus. The keynote speaker will be IRS Commissioner Douglas Shulman. Contact: Donna Cox-Davies or Roger LeMaster. • Tel: (914) 686-5599 or (202) 822-8062 • E-mail: dcox-davies@riverinc.com or rlemaster@tcpi.org • Web site: http://www.tcpi.org Global Transfer Pricing — Frankfurt. The C5 business information group will sponsor a two-day conference on minimizing corporate transfer pricing risks, with a special focus on regulatory requirements in France, Germany, India, Russia, the U.K., and the U.S. Contact: Susan Jacques. • Tel: +44 (0) 20 7878 6888 • E-mail: s.jacques@C5-Online.com • Web site: http://www.C5- Online.com/transferpricing February 26 Cyprus Double Tax Treaties — Moscow. The Moscow Times and Eurofast Global Ltd. will sponsor a seminar on confidentiality agreements, tax treaties, and exchange of information. • Tel: +7 495 232 4774, 232 1769 International Tax — Washington. The U.S. branch of the International Fiscal Association will sponsor a two-day conference on tax treaties, transfer pricing, The calendar is available online as Doc 2009-1789. Submissions to the Tax Calendar may be sent by fax to (703) 533-4646 or by e-mail to tni@tax.org. TAX NOTES INTERNATIONAL FEBRUARY 2, 2009 • 475 (C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
TAX CALENDAR financially distressed companies from a Canadian perspective, and tax-effective supply chain management. • Tel: (866) 298-9464 • E-mail: info@ifausa.org March 2 International Tax — Miami. Networking Seminars Inc. will sponsor a one-day introductory course on international taxation and taxation of foreign earnings of U.S. corporations. • Tel: (914) 874-5395 • E-mail: info@networkingseminars.net • Web site: http:// www.networkingseminars.net March 3 International Tax — Miami. Networking Seminars Inc. will sponsor a one-day intermediate course on international taxation focusing on recent U.S. rulings and changes to the international tax regulations. • Tel: (914) 874-5395 • E-mail: info@networkingseminars.net • Web site: http:// www.networkingseminars.net March 4 International Tax — Miami. Networking Seminars Inc. will sponsor a one-day advanced course on international taxation focusing on recent court decisions and U.S. and foreign tax rulings. • Tel: (914) 874-5395 • E-mail: info@networkingseminars.net • Web site: http:// www.networkingseminars.net March 9 U.S. International Tax Reporting and Compliance — Dallas. The Council for International Tax Education will sponsor a two-day seminar focusing on the latest IRS tax reporting requirements for U.S. companies with foreign operations. • Tel: (914) 328-5656 • E-mail: info@citeusa.org U.S. Infrastructure Investments — New York. ATLAS will sponsor a two-day seminar of the tax advantages of U.S. infrastructure investments, including information regarding public-private partnerships transactions. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com March 16 International Tax Forum — San Francisco. ATLAS will sponsor a two-day forum on topics including new transfer pricing regulations, strategies for repatriating foreign earnings, and FAS 48 reporting. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com March 23 U.S. Transfer Pricing — San Francisco. The Council for International Tax Education will sponsor a two-day introductory seminar on the U.S. transfer pricing rules. • Tel: (914) 328-5656 • E-mail: info@citeusa.org China Tax Update — San Francisco. The Council for International Tax Education will sponsor a two-day technical update on the latest legal, tax, and accounting issues facing companies with operations or business opportunities in China. • Tel: (914) 328-5656 • E-mail: info@citeusa.org U.S. International Tax — Seattle. ATLAS will sponsor a two-day introduction to U.S. international tax with topics including key issues involving the American Jobs Creation Act and the U.S. tax effects of generating income or losses from operations overseas. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com European and U.S. Cross-Border Financial Products — London. ATLAS and Structured Finance Institute will sponsor a two-day conference on the technical details of European and U.S. crossborder financial products. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com March 25 U.S. International Tax — Seattle. ATLAS will sponsor an intermediatelevel three-day seminar on U.S. international tax provisions using examples and case studies. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com March 30 U.S. Tax Planning — Chicago. ATLAS will sponsor a two-day seminar on tax planning in the current economic environment. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com April 2 Corporate Taxation — Washington and Webcast. ALI-ABA and the ABA Section of Taxation will cosponsor a twoday course on topics including taxable merger and acquisition structures, crossborder issues, treatment of contingent liabilities, executive compensation and compensatory interests, and structures to accommodate private equity investors. • Tel: (800) 253-6397 April 20 Taxation of Financial Products — Chicago. ATLAS will sponsor a twoday introduction to tax and accounting issues regarding financial products and derivatives. • Tel: (800) 206-4432 • Web site: http://www.atlas-sfi.com U.S. International Tax Reporting and Compliance — Atlanta. The Council for International Tax Education will sponsor a two-day course on IRS tax reporting requirements for U.S. companies with foreign operations. • Tel: (914) 328-5656 • E-mail: info@citeusa.org April 26 Offshore Companies — Miami. Offshore Alert will sponsor a three-day conference on topics including defense against IRS administrative and criminal investigations, the limits of Chapter 15, Ponzi schemes, anti-money laundering, offshore insurance products, and flagship tax investigations. Contact: Naomi Comerford. • Tel: (305) 372-6296 • Web site: http:// www.offshorealertconference.com 476 • FEBRUARY 2, 2009 TAX NOTES INTERNATIONAL (C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
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tax notes international Volume 53,
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ARGENTINA 387 Buenos Aires’ New S
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President and Publisher: Christophe
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HIGHLIGHTS from the tax accounts in
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HIGHLIGHTS However, if the firm rec
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HIGHLIGHTS NEWS ANALYSIS Multinatio
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HIGHLIGHTS check by full tax on any
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HIGHLIGHTS U.S. Widens Investigatio
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HIGHLIGHTS is required to withhold
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HIGHLIGHTS by a Canadian taxpayer a
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HIGHLIGHTS Personal Tax Measures Th
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ARGENTINA the most significant exem
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CHINA (P.R.C.) On December 16, 2008
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EUROPEAN UNION ensure that there is
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GERMANY confessed to his wrongdoing
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INDIA Addressing the assessee’s d
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INDONESIA As of January 1 and conti
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JAPAN insistence that the bill incl
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OECD OECD OECD Group Addresses CIVs
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OECD Furthermore, a source country
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PORTUGAL Extension of Portuguese Ho
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SPAIN tax authorities interpret the
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410 • FEBRUARY 2, 2009 TAX NOTES
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FEATURED PERSPECTIVES We, the taxpa
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FEATURED PERSPECTIVES he has to pay
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BOOK REVIEW smaller government. But
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418 • FEBRUARY 2, 2009 TAX NOTES
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PRACTITIONERS’ CORNER for German
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SPECIAL REPORTS reports were of the
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Page 67 and 68: SPECIAL REPORTS In essence, the fir
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