§199A for international businesses
US tax residency
US/China legal relationships
Foreign investment in U.S. real estate
Tax and transfer pricing issues in intellectual property transfers
Expatriation tax planning
GILTI v. Subpart F v. Flow-Through
CPAs and tax professionals with a focus on international issues.
Attend the only WSCPA conference focused entirely on untangling the complicated web of international taxation and ensure you have the most relevant and up-to-date information to serve businesses in today’s international marketplace.
Wednesday, June 10
Despite recent events such as the U.S.-China Trade War and the coronavirus, China remains a huge opportunity for U.S. investment. Chris Brown will orient you to the legal considerations that go into establishing a business in the Middle Kingdom along with the tax consequences that accompany it. Alternatively, for those businesses that want to leave China, learn about the legal and tax implications of exiting the Chinese market.
Commonly seen as a domestic provision, the pass-through deduction can also apply to reduce the rate of tax on foreign operations of pass-through business owners. During this session, we will trek through the eligible types of foreign income, strategies for structuring foreign operations to qualify and substantiate the benefit, and interaction of Sec. 199A with source of income and the foreign tax credit limitation.
Journey into the realm of intellectual property transfers with Deniz Kiral. He will review and share client cases that are relevant to the tax law and transfer pricing provisions necessary for firms to advise cross border, high tech clients with intellectual property. Uncover and explore a new approach to IP planning in light of significant changes in the Tax Cuts and Jobs Act.
The timing of when US residency begins and terminates is critical in any pre-immigration and expatriation tax planning. The dates will also determine the type of return that a taxpayer will be required to file. Moses Man will help us stay on track as he discusses the rules in determining these relevant dates, as well as exceptions to the general rules.
Despite the current challenges facing our economy, the United States is still viewed as a safe location for investing, as evidenced by the flight capital coming to the U.S. Make sure you are prepared to advise international clients who may be seeking to make investments in US real estate for personal or investment purposes. Ruby Banipal will discuss alternative real estate holding structures for investment in U.S. real property, as well as U.S. income and transfer tax consequences associated with the purchase, rental, sale, inheritance, or other disposition of U.S. real property.
It’s easy to misjudge the terrain when you’re dealing with Passive Foreign Investment Companies (PFICs). During this session, you’ll learn the reporting requirements and elections as well as how to identify commonly missed PFICs (e.g., in foreign pensions and retirement accounts). Plus, we’ll discuss how to make sure you’re on firm footing with the interaction of the CFC and PFIC regimes and new strategies post TCJA.
Is your client planning on renouncing their US citizenship or relinquishing a green card? Monica Langfeldt will help you methodically survey the essential issues to consider, including compliance, and planning and timing of your client’s extraction from the US tax system.
When you’re evaluating GILTI v. Subpart F v. Flow-Through considerations, does it feel as if you are stomping through a patch of noxious weeds? Ross Martin will introduce and examine factors to consider when choosing how to organize new entities and structure transactions, and help you compare results from the different options.
Chris is the principal attorney and CEO of NorthStar Law Group, P.S. where he practices in the areas of domestic and international business transactional law, complex estate planning and tax law. Prior to founding NorthStar Law Group in April 2019, he was the sole owner of Christopher T. L. Brown, Attorney at Law, PLLC since 2009. He was previously an associate attorney at Hanna Strader PC in Portland, Oregon from 2001 – 2007 and Worth Law Group, P.S. in Tumwater, Washington from 2007-2009.
Jordan Reichelt, CPA is a Senior Manager at Spott, Lucey & Wall, a CPA firm specializing in international tax and cross-border issues. His clients include many investors and entrepreneurs in the real estate, technology, and creative sectors and businesses from around the world. Jordan has developed a special focus on state and local compliance services for multinational businesses and issues involving international trusts and estates. He leads Spott, Lucey & Wall’s Seattle office and is a frequent speaker on International Tax Topics including GILTI, subpart F, and other CFC issues.
Will Skinner is a tax partner in Fenwick & West’s Silicon Valley office, with 14 years of experience as a tax attorney. He focuses his practice on corporate tax, tax structuring for enterpreneurial ventures, and international tax planning. He also extensive experience with IRS Appeals and other tax controversy matters. He is a graduate of Stanford Law School and after law school, clerked for the Ninth Circuit court of appeals.
With a global tax practice at Legamaro Banipal, Ruby Banipal provides international income, capital, estate, inheritance and gift tax-planning and implementation solutions for ultra-high-net-worth clients, their investment vehicles and related structures – principally those who are globally active, hold concentrated wealth with multi-jurisdictional assets, business and reach, and are acting for their own accounts or are the foreign financial institutions catering to and advising such wealth.
Ruby regularly works with cross-disciplinary teams in implementing international structures and investment strategies for US and non-US individuals and their families.
Ruby counsels clients on the tax implications that arise when cash, property, businesses or transactions cross borders. In this capacity, Ruby advises foreign clients on the US income, estate and gift tax consequences of alternative inbound investment structures while utilizing income, estate and gift tax treaties to minimize tax and regulatory burdens.
Often, Ruby’s clients are multi-generational families that span multiple jurisdictions, requiring an in-depth understanding of tax laws worldwide.
Previously, Ruby was an associate in the global private client practice at DLA Piper. Ruby worked regularly with counsel in Asia, Canada and Latin America to service clients that are interested in making cross-border investments.
Ruby was based out of DLA Piper’s Hong Kong office in 2014. Prior to that, she was an international tax consultant with a Big Four accounting firm based out of Chicago. She also did internships with the Internal Revenue Service Office of Chief Counsel and the Department of Justice, California Attorney General’s Office (Business/Tax Section).
Ross serves as the Global Tax Services leader for CLA’s Mountain West region. He advises on all international tax issues faced by CLA clients, inbound and outbound. Ross works with closely held businesses working through their first cross-border transactions, as well as large companies with broad international footprints. He helps clients navigate the ever-changing tax reporting requirements and advises them on tax efficient legal organization and restructuring.
After graduating from law school Monica joined PriceWaterhouseCoopers in New York City, where she advised multinationals on their tax structure, she then spent a few years with Kaye Scholer, also in New York City, while pursuing her LL.M in Taxation at NYU before moving west to finish her LL.M at UW.
Upon completing of her LL.M, Monica joined Miller Nash, a premier northwest law firm, where she practiced in the area of corporate law, international, federal, state and local tax law as well as provided guidance to numerous tax-exempt and for-profit organizations.
Prior to opening her own firm she was a partner at Garvey Schubert Barer, an international law firm, headquartered in Seattle, Washington. At Garvey Schubert Barer, Monica honed her corporate counsel skills as well as expanded her knowledge of all areas of the tax law.
Monica grew up in Norway and speaks fluent Norwegian and is active in the local Norwegian community in Seattle. She is a past Adjunct Professor at Seattle University School of Law, where she taught international tax law. In her spare time, she tries to fit in as much hiking, running, skiing, snowboarding and cooking as she can manage, all to the delight of her husband and four-legged companions Scout and Indie.
Moses Man, CPA, is the CEO of M Squared Tax PLLC, a CPA firm specializing in international taxation. His practice focuses on US international tax planning for small to mid-size multinationals across all industries, including technology, manufacturing, and professional services. He also has experience with US individual expatriate tax planning and pre-immigration tax planning for inbound foreigners. Prior to launching M Squared Tax, Moses spent 11 years at national and regional accounting firms serving multinational companies, including startups, venture capital funds, and Fortune 500 companies. Moses earned his B.A. from Seattle University and his Master’s in Taxation from the University of Washington. Moses serves as an adjunct accounting and tax professor at both Seattle University and the University of Washington and he is a current advisory board member at the Bellevue College Accounting Program.
Deniz Kiral, CPA, MSF, MA is an international tax advisor and founder of the Washington CPA firm of Turquoise Tax Advisory in Seattle. Deniz’s practice advises clients with the international tax aspects of corporate structuring, transfer pricing, compliance and cross border high net worth planning. His experience includes private equity cross border structuring, cross-border restructuring engagements for Fortune 500 companies to manage their global effective tax rate. He also provides cross border private client services for ultra-high net worth clients primarily in Asia with pre-immigration and estate planning.
Non-Member Price $415.00
Member Price $315.00