Focus on the Principles Relating to the Taxation of Foreign Persons
This basic seminar in international taxation will focus on the principles relating to the U.S. taxation of foreign persons (individuals as well as legal entities) and the U.S. taxation of income received by U.S. individuals and entities from activities abroad. Topics will include principles of international tax jurisdiction; rules relating to the source of income and deductions; the foreign tax credit; Section 482 and transfer pricing; an introduction to controlled foreign corporations; and international double taxation treaties. The seminar will then focus on current developments including FATCA and international tax reform proposals.
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Number of Units: 4 MCLE's and Legal Specialization credits in Taxation Law
University of San Diego School of Law is a State Bar of California approved provider of MCLE and Legal Specialization in Taxation Law credits and certifies that this activity is approved for 4.0 hours of general MCLE and 4.0 hours of Legal Specialization in Taxation Law.
Instructor: John I. Forry, JD, is the Director of Tax Programs and Professor-in-Residence, University of San Diego School of Law. As director of tax programs, Forry oversees the LLM in Taxation program and leads efforts to expand the reach and reputation of other tax programs at USD School of Law, including continuing education programs and established events. Forry also teaches graduate-level courses in international finance and taxation. Forry received his JD from Harvard Law School.
Jaclyn Jacobs Pampel is a Partner with Baker & McKenzie LLP. Her extensive tax experience involves advocating for clients in all stages of tax controversies, advising companies facing potential tax controversies pre-audit, during the audit and administrative appeals, and during alternative dispute resolution proceedings and in U.S. Tax Court. Ms. Pampel frequently speaks and gives seminars on various aspects of Federal tax controversies and negotiation strategies. She regularly teaches advocacy skills to government, public interest, and private firm lawyers. Ms. Pampel is dedicated to providing pro bono legal services with a focus on criminal defense work. Her pro bono efforts include serving as defense counsel in a first degree murder trial in Cook County Criminal Court in Chicago, Illinois. Ms. Pampel is admitted to practice in Califonia and Illinois.
Who Should Attend: Tax attorneys, CPA’s, Enrolled Agents, or any individual responsible for managing or overseeing a firm’s tax practice.