The International Tax Institute, Inc. holds monthly seminars in mid-town Manhattan on current subjects of international tax law.
We provide New York State continuing legal and professional education (non-transitional CLE and CPE) credits to international tax attorneys and accountants. Founded in 1961, we are a 501(c)(3) organization.
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Wednesday, March 18, 2015
"Navigating the Subpart F Services Rules"
Most of the Subpart F rules that apply to services income date back to the 1960s, and were designed for limited types of services—such as building dams and highways, and providing maintenance services for machines sold by related parties. Today, service businesses are a major sector of the global economy—including technology, consulting, financial, e-commerce, software—and applying outdated Subpart F rules to modern services paradigms is challenging.
The panel will discuss global structures used by multinationals to minimize Subpart F services income. It will also address difficulties in applying the Subpart F rules, including determining when a CFC is performing services “on behalf of” a related person, calculating the cost test of the substantial assistance rule, and identifying the location where services are performed for purposes of the same-country definitional limitation. Marjorie Rollinson, IRS Deputy Associate Chief Counsel (International), will provide commentary on these issues and discuss developments
Time: 12:15 p.m. to 2:00 p.m.
Cost: $100 for members and $140 for non-members
Location: Grand Hyatt New York at 109 East 42nd Street, New York, NY
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Alston & Bird LLP
The Bank of Tokyo-Mitsubishi UFJ, Ltd.
Blake, Cassels & Graydon LLP
Boies, Schiller & Flexner LLP
Bryan Cave LLP
Cadwalader, Wickersham & Taft LLP
Capita Asset Services (US)
CBIZ MHM, LLC.
Cleary Gottlieb Steen & Hamilton LLP
Curtis, Mallet-Prevost, Colt & Mosle LLP
Davies Ward Phillips & Vineberg LLP
Dentons US LLP
Ernst & Young
Fox Horan & Camerini LLP
Gide Loyrette Nouel LLP
Greenberg Traurig LLP
Holland & Knight LLP
International Business Company Formation, Inc.
Kaye Scholer LLP
Kilpatrick Townsend & Stockton LLP
Kostelanetz & Fink LLP
Loyens & Loeff
Machado Meyer Sendacz e Opice Advogados
Marks Paneth & Shron LLP
Mayer Brown LLP
McDermott, Will & Emery LLP
Osler, Hoskin & Harcourt LLP
PKF O'Connor Davies
Proskauer Rose LLP
Roberts & Holland LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Stroock & Stroock & Lavan LLP
Sullivan & Cromwell LLP
Tozzini, Freire, Teixeira e Silva Advogados
Viacom International, Inc.
Weil, Gotshal & Manges LLP
Winston & Strawn LLP