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International Tax Conference 2025 IN PERSON

Select your sessions

Thursday, May 15

General Session

General Session

General Session

Explore the intricacies of trust planning for Non-Resident Aliens (NRAs) with US-based beneficiaries or US-source income and real estate holdings. You will gain insights into key strategies for effectively structuring trusts to meet tax, legal, and estate planning objectives.

General Session

General Session

Explore the impact of the Tax Cuts and Jobs Act (TCJA) on Subpart F, including anticipated changes to Subpart F rules for the 2025 tax year. You will also learn about the application of Section 962 in the context of Subpart F and its relevance to pass-through entities and individuals, focusing on key compliance and planning strategies.

General Session

Breakout Session

Explore the key considerations and strategies for inbound real estate investments. Gain practical insights into navigating the complexities of cross-border real estate transactions and maximizing opportunities for foreign investors.

Delve into the complexities of State and Local Tax (SALT) issues in the realm of international tax planning. This high-level exploration will uncover how state and local tax regulations intersect with cross-border transactions, global business structures, and international tax strategies. Gain valuable insights into the impact of SALT considerations on multinational operations and the strategic decisions that drive global tax planning.

General Session

General Session

General Session

Gain an overview of the complex regulations surrounding when you should and should NOT consider check the box regulations for a foreign corporation. Learn key tax considerations, common pitfalls, and strategies for navigating the intricacies of these regulations.  You will leave with a clearer understanding of how these regulations affect their foreign corporate structures and their tax obligations.

General Session

General Session

Learn about Schedule J of Form 5471, including the reporting of earnings and profits (E&P) for controlled foreign corporations (CFCs). Gain a high-level understanding of the key compliance requirements, common challenges, and best practices for accurate E&P reporting, along with an update on recent changes to the form.

General Session

Breakout Session

The United States is one of the few countries that imposes taxation based on citizenship and residency, creating complex compliance and planning obligations for U.S. citizens and lawful permanent residents living abroad. These individuals are subject to worldwide income reporting, gift and estate tax exposure, and increasing IRS enforcement efforts.
This session provides tax advisors and international estate planners with critical insights into U.S. tax obligations and strategic exit planning for U.S. persons considering expatriation. Special attention will be paid to mixed nationality households and the unique risks they face if proper planning is not undertaken.

General Session

General Session

Explore the latest IRS developments alongside an analysis of the Bruyea case and its implications. We’ll consider both legal and accounting perspectives on the controversy, and unpack its impact on tax regulations, compliance practices, and industry standards.

General Session

General Session

General Session

Let’s take a strategic look at key Canada-U.S. tax considerations in cross-border entity structuring. Delve into the tax implications, compliance requirements, and effective planning strategies to optimize efficiency and mitigate risks for businesses and individuals.