State Taxation Issues for Foreign Operating Companies
Overview:In a two hour live webcast, a panel of thought leaders and practitioners assembled by The Knowledge Group will discuss the significant and latest issues on state taxation issues for foreign operating companies including:
- Income Apportionment Amongst States
- Transfer Pricing In Relation to Sec. 483 Powers
- Indirect Tax Issues
- Tax Jurisdiction
- Unitary Business and Combined Reporting
- Party Interest and Royalty Add Back
- State Taxation of Foreign Source Income
- Tax Collection and Enforcement
State Taxation Issues for Foreign Operating Companies LIVE Webcast is a must attend for tax attorneys and other professionals interested in and/or responsible for state tax foreign operation. The program will cover the topics above along with a Q&A panel in which the attendees will be invited to ask the speakers questions.
Segment 1 :
David A. Hughes , Partner
Horwood Marcus & Berk Chartered
- Jurisdiction to Tax (Nexus)
- Note special foreign Commerce Clause rules
- Unitary Business and Combined Reporting (including worldwide combined reporting and 80/20 rules)
- Related Party Interest and Royalty Add Back
- State Taxation of Foreign Source Income (dividends, gross up, subpart F, sec. 1248 income)
- Tax Collection and Enforcement
Segment 2 :
A. Hunter Bywaters III, Director, State Income and Franchise Tax Practice
- General discussion about how income is apportioned amongst the states – specifically the effect of states moving to a single sales factor on inbound companies;
- Transfer pricing – states with IRC Sec. 482 powers;
- Indirect tax issues – sales and use taxes along with franchise tax, real estate transfer taxes, etc. at the state and local levels.
Who Should Attend:
- Tax Preparers
- Enrolled Agents
- Tax Consultants/managers
- Tax Attorneys
- Tax Advisers
- Finance Executives
- Multinationals (Public and Private)
- And Other Interested Professionals
DAVID A. HUGHES is a partner in Horwood Marcus & Berk’s State and Local Tax (SALT) Group. David’s clients, who range from multinational corporations to individuals, all have one thing in common: the need to limit their state and local tax exposure either through planning or litigation. David advises clients on how to structure their business to reduce their state tax liabilities and he also defends clients in audits, administrative proceedings and court against tax assessments.
David has represented clients in over 30 states and has advised clients on income tax, sales/use tax, franchise tax, and unclaimed property matters, including matters involving nexus, apportionment, business income, unitary business groups, credits, losses, exemptions, and the tax base. David has argued cases at the Illinois Supreme Court, the Illinois Appellate Court and the New York Supreme Court (Appellate Division).
In addition to representing clients on a national basis, David is also very active in the SALT community. He is the former Chair of the SALT committee for the Illinois CPA Society and the former chair of the Chicago Bar Association’s committee on state and local taxation. David also speaks and writes regularly on SALT matters. He is a co-author of the chapter entitled “Illinois Sales and Use Tax” in the American Bar Association’s Sales and Use Tax Handbook and is on the Editorial Board of the Journal of Multistate Taxation and Incentives. In addition, he has spoken on behalf of NYU’s School of Continuing and Professional Studies, the Council on State Taxation (COST), Tax Executives Institute (TEI), the American Bar Association, the Institute of Professionals in Taxation (IPT), the Illinois CPA Society, and the Chicago Tax Club.
DAVID A. HUGHES is a partner in Horwood Marcus & Berk’s State and Local Tax (SALT) Group. David’s clients, who …
A. Hunter Bywaters III is a Director for Ryan’s State Income and Franchise Tax practice in the Firm’s Dallas office. Mr. Bywaters specializes in providing multistate income and franchise tax services to clients in a variety of industries. His expertise includes specialization in Texas franchise tax refund reviews and audit defense. Before joining Ryan, Mr. Bywaters served as a director, manager, senior consultant, and associate consultant at a national accounting firm. He also served as a legal intern in the Office of the United States Trustee Program, Legal Division. Mr. Bywaters lectures on various tax topics for Ryan clients. Additionally, he has appeared as a speaker for the Dallas CPA Society and Tax Executives Institute. Mr. Bywaters is also affiliated with the American Heart Association and Texas Taxpayers and Research Association. Mr. Bywaters holds a Juris Doctor degree from Boston College, a Graduate Diploma in Management from McGill University
A. Hunter Bywaters III is a Director for Ryan’s State Income and Franchise Tax practice in the Firm’s Dallas office. …
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About Horwood Marcus & Berk Chartered
HORWOOD MARCUS & BERK CHTD. combines the resources of a national and sophisticated commercial law practice with the entrepreneurial atmosphere and creativity unique to a smaller law firm. HMB attorneys have served as trusted business and legal advisers to middle-market businesses, Fortune 500 companies, entrepreneurs, individuals and families throughout the United States for almost 40 years.
Formed in 1975 as a Chicago-based tax boutique providing specialized tax planning for individuals and businesses, HMB has evolved into a full-service law firm providing legal counsel and pragmatic business solutions to a wide range of corporate, business and individual clients.
HMB strongly believes that simplicity is a virtue. The firm keeps its client engagement teams deliberately small and closely knit to control costs and deliver consistently better and more reliable client service. Simply put, HMB attorneys are dedicated, responsive and accessible.
About Ryan, LLC
Ryan is an award-winning global tax services firm, with the largest indirect and property tax practices in North America and the sixth largest corporate tax practice in the United States. Headquartered in Dallas, Texas, the Firm provides a comprehensive range of state, local, federal, and international tax advisory and consulting services on a multi-jurisdictional basis, including audit defense, tax recovery, credits and incentives, tax process improvement and automation, tax appeals, tax compliance, and strategic planning. Ryan is a three-time recipient of the International Service Excellence Award from the Customer Service Institute of America (CSIA) for its commitment to world-class client service. Empowered by the dynamic myRyan work environment, which is widely recognized as the most innovative in the tax services industry, Ryan’s multi-disciplinary team of more than 1,700 professionals and associates serves over 9,000 clients in 40 countries, including many of the world’s most prominent Global 5000 companies. More information about Ryan can be found at www.ryan.com.