TCAJA introduced two alternative tax regimes available to U.S. based businesses serving foreign markets. The two regimes are the Foreign Derived Intangible Income (FDII) available only to domestic C corporations and Qualified Business Income (QBI) Deduction (§199A). FDII offered a 13.125% effective corporate tax for C corporations. QBI offers an effective rate of 29.6% to individuals and noncorporate owners of passthrough business entities. These two essentially alternative and mutually exclusive concepts need to be considered by practitioners advising clients with foreign customers. Both provisions with emphasis on FDII will be illustrated with worked examples reflecting the latest available guidance. Read more
In many cases GILTI eliminates meaningful opportunities for deferral of U.S. Federal income tax on foreign earnings of U.S. owned foreign corporation and essentially imposes a 10.5% minimum tax.Under final regulations issued in June 2019, complex issues of computing the current inclusion, return of qualified business asset investment, high tax exception for Subpart F income and related foreign tax credit issues are addressed. The webinar will cover the more significant provisions of the regulations with worked examples and planning suggestions. Read more
CLA Taxation Section members get the member rate with the promocode CLA 2.0 MCLE Credit; 2.0 CPE Credit Tuesday, July 23, 2019, 12 noon - 2 p.m. This Webinar timely reviews the finalized centralized partnership audit regime regulations promulgated by the IRS in final form on February 27, 2019. Understand how the new regime will be implemented in conjunction with previously-promulgated rules allowing for an election out of the regime. Learn how to identify critical operational provisions and effectively navigate… Read more
Elliott Gold will discuss the recent changes to Canadian trademark legislation including, Canada’s recent adherence to the Madrid Protocol, the Adoption of the Nice Classification system, recommended steps for U.S. trademark applicants, tips for IP due diligence investigations for Canadian transactions, Canadian and Global Brand Protection and border enforcement strategies. Read more
New laws, evolving socio-cultural norms and new expectations of workplace civility have posed new challenges for both employees and employers in the workplace. Learn about the benefits of the highly successful national mediation program at the EEOC that efficiently and effectively resolves workplace disputes. Read more
This program offers 1 hour participatory MCLE credit. You must register in advance to participate. Learn about the implications of decisions in the October 2018 term and preview key upcoming cases to be decided beginning October 2019. Moderator: Seth Kugler. Speaker: Anne Voigts. Read more
This program will explore a civil writ practice, procedures and techniques. Panelists will teach you the criteria used for granting or denying a writ petitions, and how to avoid common drafting mistakes. Read more
This program offers 1 participatory MCLE credit. You must register in advance to participate: https://bit.ly/2ROEoHo Historically, there was uncertainty whether California prohibited out-of-state and foreign lawyers to provide legal services in international commercial arbitrations conducted in California. Such uncertainty created a significant disincentive to the selection of California as an international arbitration venue and prevented the development of a true international arbitration practice in the state. However, on July 18, 2018, California Governor Jerry Brown signed into law SB 766… Read more