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Subpart F – Developments, Planning Opportunities & Audit Strategies
Thursday, September 6, 2012 from 9:00 AM to 3:30 PM (PDT)
Santa Clara, CA
Back once again by popular demand, we are pleased to announce that Lowell Yoder and Fred Chilton from McDermott Will & Emery LLP will be featured in an intermediate to advanced ¾ day seminar on important subpart F topics.
At this not-to-be-missed seminar, Lowell and Fred, along with Jeff Shore and Dave Noren, will cover new developments and planning considerations that involve the topics listed below. In addition, they will discuss current IRS subpart F audit trends and the impact of legislative and other related developments on various subpart F planning opportunities and audit strategies. While important background information will be highlighted for each topic, the presentations will move quickly from the basics to a detailed discussion of recent developments and IRS trends in these areas.
The following topics will be covered:
· Income Characterization
· Foreign Personal Holding Company Income
· Foreign Base Company Income (Sales, Services)
· Sections 956 and 959
· Legislative and Related Developments
Speakers from McDermott Will & Emery LLP
Lowell D. Yoder, Head of the U.S. & International Tax Practice Group (Chicago)
Fredrick R. Chilton, Managing Partner, Silicon Valley Tax Practice (Menlo Park)
Jeffrey L. Shore, Counsel (Menlo Park)
Dave G.Noren, Partner (Washington, D.C.)