A live 100-minute audio conference from CCH and PricewaterhouseCoopers LLP covers the ins and outs and latest developments in the incentives for corporations to reinvest foreign earnings under the American Jobs Creation Act of 2004 (AJCA).
AJCA Repatriation Provision With the massive AJCA, Congress sought to boost investment in the U.S. with a remarkable - and short-lived - provision to create incentives to reinvest foreign earnings in the United States. Tax professionals have been scrambling to learn how this provision works and the IRS is continuing to interpret and create rules for the use of this incentive, which will not be available after the 2005 tax year.
Adding to the uncertainty for corporate tax departments is the 35-percent tax hit corporations will take if they conclude incorrectly that a dividend is eligible for repatriation provisions of the AJCA - a tax that would otherwise have not been paid if the repatriation wasn't attempted.
Repatriation Incentive Expires after 2005 The new repatriation provision is a one-year-only opportunity under which certain dividends received by a U.S. corporation from controlled foreign corporations and reinvested in the U.S. are eligible for an 85-percent dividends received deduction (DRD), generally resulting in a maximum tax rate on such dividends of only 5.25 percent. So despite the pitfalls, the potential payoff in tax savings can be substantial for corporations that choose to leverage this incentive.
PwC Experts PricewaterhouseCoopers’ corporate and international tax professionals have followed this incentive from day one and continue to monitor IRS and Treasury activity so they can offer up-to-the minute insights into the rules and regulations being drafted for this incentive. These same professionals will lead you through the provisions of the incentives, outline the massive opportunities for your company and — most importantly — discuss ways to help you navigate through the minefields of this short-lived and tricky corporate income tax incentive.
Here are some of the items you’ll learn about:
Common problems encountered in planning for repatriation
Minimizing withholding taxes, including use of disregarded entities
The do's and don'ts of creating a Domestic Reinvestment Plan
Why OFL and NOL companies should consider repatriation
Divestiture opportunities
Developing a critical path to timely complete your repatriation plan
About The Speakers
Michael Urse, JD, CPA: Urse, a partner who leads the International Tax Services group of PricewaterhouseCoopers’ Global Tax Structuring practice in Cleveland, Ohio, and is national leader of PricewaterhouseCoopers’ U.S. Outbound team. The U.S. Outbound team designs and implements foreign debt restructuring solutions, and helps the firm’s U.S. clients optimize their use of foreign tax credits. Michael has extensive experience in the development of strategies to increase foreign source income, and to minimize foreign source expenses.
Alan L. Fischl, JD: Fischl is an international tax partner with PricewaterhouseCoopers’ Washington National Tax Services office. He consults with the firm's practice offices and clients on international tax issues arising in complex transactions, tax planning and controversies with the IRS. He has also served as leader of the Washington National Tax Services Energy and Mining Industry practice.
Tadd A. Fowler, CPA: Fowler is an International Tax Services (ITS) Partner in PricewaterhouseCoopers’ Global Tax Structuring practice with more than 14 years experience with multinational companies in structuring international operations. He is one of the firm’s lead ITS partners, having overall co-leadership responsibilities for the firm’s US Outbound practice. Tadd has extensive experience in designing and implementing solutions designed to optimize the global tax position of multinational companies.
Free Book Included With Registration With your registration, you will receive one free copy of the American Jobs Creation Act of 2004: Law, Explanation and Analysis from CCH's expert tax editors. This 1,200-page book is a $65 value and is free to each site that registers. Your book will be shipped as soon as possible, but sign up early to ensure your book arrives on time for the conference.
How it Works CCH's live audio conferences require nothing more than a telephone connection. For the $299 per site fee, you can have an unlimited number of listeners at your site get up to speed and in-the-know on this fast-changing topic.
CPE Two hours of CPE credit are also available for an additional $25 for each person wishing to receive a CPE certificate for their participation in the conference.
