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International Tax Conference 2025 IN PERSON

Select your sessions

Thursday, May 15

General Session

General Session

General Session

This session will explore the intricacies of trust planning for Non-Resident Aliens (NRAs) with US-based beneficiaries or US-source income and real estate holdings. Attendees 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. Attendees 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

This session provides a strategic overview of key Canada-U.S. tax considerations in cross-border entity structuring, covering tax implications, compliance requirements, and planning strategies to optimize efficiency and mitigate risks for businesses and individuals.

Delve into the complexities of State and Local Tax (SALT) issues in the realm of international tax planning. This session offers a high-level exploration of how state and local tax regulations intersect with cross-border transactions, global business structures, and international tax strategies. Attendees will 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

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

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.  The session will highlight key tax considerations, common pitfalls, and strategies for navigating the intricacies of these regulations.  Attendees will leave with a clearer understanding of how these regulations affect their foreign corporate structures and their tax obligations.

General Session

General Session

This session will provide an overview of Schedule J of Form 5471, focusing on the reporting of earnings and profits (E&P) for controlled foreign corporations (CFCs). Attendees will 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

General Session

General Session

General Session

Examine the critical tax issues surrounding expatriation, including the legal and financial implications of renouncing U.S. citizenship or long-term residency. This session will cover compliance requirements, tax strategies, and the long-term impact of expatriation decisions.

General Session

General Session