The Treasury and the IRS are in the process of finalizing the laws concerning contract manufacturing arrangements as per the anti-deferral regime Subpart F. Set to take effect for tax years of foreign controlled companies beginning after June 30th, 2009, the new guidance aims to update and modernize the contract manufacturing regs under Subpart F. While the Regs are generally well received by tax payers, there is much confusion surrounding key areas such as: retention of the fundamental approach, clarification of personal property sale issues, and turnkey CFC’s to name a few.
A panel of key thought leaders and contract manufacturing experts will discuss the final guidance and its impact on your firm. Understanding the IRS New Contract Manufacturing Rules LIVE Webcast is a must attend webcast for companies who utilize contract manufacturing arrangements seeking to understand the fundamentals of and how it may apply to their company.
Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Conference
Recommended CLE/CPE Hours: 2.0
Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.
Advance Preparation: Print and review course materials
Course Code: 093887
Ethan Atticks
Senior Technical Reviewer of Branch 2, Office of the Associate Chief Counsel (International)
Carol P. Tello
Partner (Former Special Assistant to the Assistant Commissioner (International), Internal Revenue Service)
William P. Elliott, CPA,. ABV/CVA, J.D.,LL.M.
Partner and Firm Director of International Tax
H. David Rosenbloom
Member, (Former International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of Treasury)
Ethan Atticks, Senior Technical Reviewer of Branch 2, Office of the Associate Chief Counsel (International), Internal Revenue Service
** Speaker Agenda to be added soon.. **
William P. Elliott, CPA,. ABV/CVA, J.D.,LL.M., Partner and Firm Director of International Tax, Cherry, Bekaert & Holland, L.L.P.
- Effect of New Contract Manufacturing Regulations on Supply Chain Structures
- U.S. Treatment of Import and Contract Processing Arrangements Under Contract Mfg. Prop. Regs.
- Adjusting Foreign (non-U.S.) Contract Mfg. Structures for New Rules
- “Turnkey” manufacturing and ODM arrangements.
- Automated manufacturing
- Unrelated-to-unrelated structures.
Carol P. Tello, Partner, Sutherland Asbill & Brennan LLP (Former Special Assistant to the Assistant Commissioner (International), Internal Revenue Service)
- Dealing with the branch rules
- Planning for repeal of international check-the-box
- Impact of OECD Business Restructurings Draft Report
H. David Rosenbloom, Member, Caplin & Drysdale (Former International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of Treasury)
- Relationship of the contract manufacturing rules and the branch rule
- Subtleties of the "substantial contribution" factors
- Rejection of the "Its" defense
- Missing definition of a "branch"
- The multiple manufacturing location rules
- Tax rate disparity test
- Calculation of tainted branch income
- Manufacturing Attorneys
- Contract Manufacturing Experts
- International Tax Counsel and Directors
- Finance Team
- Tax Attorneys
- Senior Management
This is a must attend event to everyone to hear the latest development on IRS new contract manufacturing rules
- Detailed guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A