Previous Events & CLE Programs
December 5, 2007
Committee Meeting
Impact of New Protocol to the U.S.-Canada Income Tax Treaty on Northbound and Southbound Transactions
Sponsors
Federal Tax & Business Transactions Committee
International Tax Committee
On September 21, 2007, the United States and Canada, after many years of negotiations, signed a new Protocol to amend the Convention between Canada and the United States of America with Respect to Taxes on Income and Capital. When this Protocol becomes effective, it will create both new opportunities and potential pitfalls in structuring cross-border transactions between the United States and Canada, including both “northbound” and “southbound” investments and acquisitions.
We will be privileged to have Frédéric Harvey and Marc G. Darmo from the Montréal office of the Canadian law firm of McCarthy Tétrault discuss the implications of the new Protocol from the Canadian legal and tax perspective.
February 8, 2007
Committee Meeting
Commentary on the Proposed Regulations Under Section 987
Lewis Greenwald, a partner at Sullivan and Worcester LLP, will summarize the Proposed Regulations under Section 987 and their potential impact while offering some thoughts on managing foreign currency issues.
The rules under Section 987 impact every company that has a branch outside the US. The currency rules under that provision can have an impact on companies’ financial statements as well as their tax returns. Managing these issues takes careful planning. This program will address some of the most recent guidance that was issued in the form of proposed regulations.
November 9, 2006
Committee Meeting
Section 7874 Anti-inversion Rules
Lewis J. Greenwald, a partner at Sullivan & Worcester LLP, will discuss the Section 7874 anti-inversion rules and their impact on tax planning for multinational corporations.
October 12, 2006
Committee Meeting
Recent Developments in International Tax
Co-Chairs Dave Flanagan of Teradyne and Mike Hardgrove of PricewaterhouseCoopers will discuss the following recent developments in international tax:
- The TIPRA look-through provisions in Sec. 954(c)(6)
- The Technical Taxpayer Rules
- Sec. 367(b) changes
- Proposed PTI regulations
September 14, 2006
Committee Meeting
Business Purpose and Economic Substance following the Coltec and Castle Harbor Cases
Stephen E. Shay, partner at Ropes & Gray LLP, will discuss the Coltec and Castle Harbor case decisions which indicate that taxpayers can comply with the letter of the law, yet still fail to receive the tax benefits of their structure. He will examine the impacts of this approach on international tax planning structures.
|
