Upcoming Events

2012

ALI-ABA Corporate Tax Program
Cross-Border Considerations: U.S. Tax Issues in Acquisitions of Non-U.S. Operations

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

Past Events

2012

PLI’s International Tax Issues 2012: Planning in an Uncertain World Program
Panel: Detailed Discussion of Section 909 Regulations on Foreign Tax Credit Splitting

Speakers: Lowell D. Yoder
Location: New York, NY
Practice Areas & Industries: International Tax , Tax

PLI’s International Tax Issues 2012
The New Foreign Tax Credit Rules – Splitters and Covered Asset Acquisitions

Speakers: Lowell D. Yoder
Location: New York, NY
Practice Areas & Industries: International , International Tax , Tax

2011

GW Law - IRS 24th Annual Institute on Current Issues in International Taxation
Inbound and Outbound Developments: New Today and Coming Tomorrow

Speakers: David G. Noren
Location: Washington, D.C.
Practice Areas & Industries: International , International Tax , Tax

GW/IRS 24th Annual Institute on Current Issues in International Taxation
Issues Arising Under Section 1248

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

DC Bar Association International Tax Committee of the Taxation Section Luncheon Program
International Tax Reform -- Technical and Policy Issues

Speakers: David G. Noren
Location: Washington, D.C.
Practice Areas & Industries: International , International Tax , Tax

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2011

Speakers: Peter L. Faber , Philip J. Levine , Stephen E. Wells , Lowell D. Yoder
Location: Los Angeles, CA
Practice Areas & Industries: International Tax , Tax

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2011
Cross-Border Mergers, Virtual Mergers, Post-Acquisition Integration and Other International Issues

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

BNA/CITE's: Tax Aspects of International Acquisitions & Reorganizations

Speakers: Robert A. Clary , II
Location: Chicago, IL
Practice Areas & Industries: International Tax , Mergers & Acquisitions , Tax , Tax - Acquisitions & Restructurings

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2011

Speakers: Peter L. Faber , Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

New York University's 70th Institute on Federal Taxation
Implications of Canal Corporation for Structuring Partnership Transactions

Speakers: Andrea Macintosh Whiteway
Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

University of Chicago Law School, 64th Annual Federal Tax Conference
The Future of Foreign Tax Credit

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

Tax Executive's Institute: Mergers & Acquisitions – Cross-border Opportunities & Pitfall

Speakers: Robert A. Clary , II
Location: Chicago, IL
Practice Areas & Industries: International Tax , Mergers & Acquisitions , Tax , Tax - Acquisitions & Restructurings

The Chicago Tax Club 58th Annual Fall Seminar
Intangible Property Planning: International and Federal Viewpoints

Speakers: Kristen E. Hazel , Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2011

Speakers: Peter L. Faber
Location: New York, NY
Practice Areas & Industries: International Tax , Tax

BNA/CITE's: Intermediate U.S. International Tax
Foreign Mergers & Acquisitions – Section 367(b) including Section 1248

Speakers: Robert A. Clary , II
Location: Chicago, IL
Practice Areas & Industries: International Tax , Mergers & Acquisitions , Tax , Tax - Acquisitions & Restructurings

New York University's 70th Institute on Federal Taxation
Implications of Canal Corporation for Structuring Partnership Transactions

Speakers: Andrea Macintosh Whiteway
Location: New York, NY
Practice Areas & Industries: International Tax , Tax

ABA 2011 Joint Fall CLE Meeting
Foreign Activities of U.S. Taxpayers; Principal Structures Are Not Just for Manufacturers – Planning for Service Providers Under Subpart F

Speakers: Lowell D. Yoder
Location: Denver, CO
Practice Areas & Industries: International Tax , Tax

ABA 2011 Joint Fall CLE Meeting
Principal Structures Are Not Just for Manufacturers – Planning for Service Providers Under Subpart F

Speakers: Lowell D. Yoder
Location: Denver,CO
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute, New York Chapter Meeting
Interchange and Merchant Discount Fees - Update

Speakers: Elizabeth Erickson
Location: New York, NY
Practice Areas & Industries: International Tax , Tax

15th Cross Atlantic and European Tax Symposium
Controlled foreign company provisions in the U.S. and UK

Speakers: Lowell D. Yoder
Location: London, England
Practice Areas & Industries: International Tax , Tax

BNA Tax Management Advisory Board Meeting
Designing a Territorial Tax System for the United States

Speakers: David G. Noren
Location: New York, NY
Practice Areas & Industries: International Tax , Tax

IFA USA New York Region International Tax Seminar
Panel: Subpart F Planning for Services

Speakers: David G. Noren
Location: New York, NY
Practice Areas & Industries: International Tax , Tax

TEI Atlanta 2011 International Tax Course
Foreign Tax Panorama

Speakers: Lowell D. Yoder
Location: Atlanta, GA
Practice Areas & Industries: International Tax , Tax

BNA/CITE's: Tax Aspects of International Acquisitions and Reorganizations
Internal Restructurings: Section 304 Issues

Speakers: Robert A. Clary , II
Location: New York, NY
Practice Areas & Industries: International Tax , Tax , Tax - Acquisitions & Restructurings

Tax Executives Institute: EMEA Chapter Spring Conference 2011
Education Day

Speakers: Peter Bauschatz , Hervé Bidaud , Gero Burwitz , Mario Martinelli , Peter M.W. Nias , David G. Noren , Carlo Maria Paolella , Dirk Pohl , James Ross , Andrea Tempestini , Lowell D. Yoder
Location: Geneva, Switzerland
Practice Areas & Industries: International Tax , Tax , Tax - Germany , Tax - Italy , Tax - London

TEI EMEA Chapter Spring Conference 2011

Speakers: Peter Bauschatz , Gero Burwitz , Annette Keller , Mario Martinelli , Peter M.W. Nias , David G. Noren , Carlo Maria Paolella , Dirk Pohl , James Ross , Andrea Tempestini , Lowell D. Yoder
Location: Geneva, Switzerland
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute
International Tax Planning: Section 338 Elections for Foreign Targets

Speakers: Robert A. Clary , II
Location: Houston, TX
Practice Areas & Industries: International Tax , Tax

Chicago Tax Club
Foreign Tax Credit Splitters

Speakers: Robert A. Clary , II
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

2011 Annual Conference of the USA Branch of the International Fiscal Association

Speakers: Steven P. Hannes
Location: Atlanta, GA
Practice Areas & Industries: International Tax , Tax

ABA Tax Section Mid Year Meeting
Current developments in Corporate Taxation

Speakers: Philip J. Levine , Timothy S. Shuman
Location: Boca Raton, FL
Practice Areas & Industries: International Tax , Tax

2010

The George Washington University and IRS 23rd Annual Institute on Current Issues in International Taxation
Inbound and Outbound Update: What’s New and What’s Coming?

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2010 Seminar
Current Issues in Divisive Strategies - Spin-Offs and Synthetic Spin-Offs

Speakers: Stephen E. Wells
Location: Beverly Hills, CA
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute International Tax Forum

Speakers: Kristen E. Hazel , Damon M. Lyon , Sandra P. McGill , Peter M.W. Nias , David G. Noren , Barry J. Quirke , James A. Riedy , PC
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2010
Cross-Border Mergers, Virtual Mergers, Post-Acquisition Integration and Other International Issues

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International , International Tax , Mergers & Acquisitions , Tax

The Chicago Tax Club 57th Annual Fall Seminar
Subpart F

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

BNA's Tax Treatment of Loan Guarantees: A Multijurisdictional Perspective

Speakers: Peter M.W. Nias
Location: Webinar
Practice Areas & Industries: International Tax , Tax , Tax - London

Congress of the International Fiscal Association 2010 Conference
The Subsidiary as Permanent Establishment of Its Parent

Speakers: Steven P. Hannes
Location: Rome, Italy
Practice Areas & Industries: International Tax , Tax

TEI 2010 International Tax Course
Foreign Tax Panorama

Speakers: Lowell D. Yoder
Location: Atlanta, GA
Practice Areas & Industries: International Tax , Tax

IFA USA Branch – Midwest Region International Tax Seminar
Moderator

Speakers: Damon M. Lyon
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

District of Columbia Bar Taxation Section/International Tax Committee's Recent and Looming Legislation Affecting International Tax Seminar
Moderator

Speakers: David G. Noren
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

Northwestern's International Tax Reform in a Reset Economy Symposium
Incremental versus Fundamental Reform

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

CITE's U.S. International Tax Planning 2010
How the Subpart F Anti-Tax Deferral Rules Operate

Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

CITE's U.S. International Tax Planning 2010
Computing Direct and Indirect Foreign Tax Credit Benefits

Speakers: Frederick Chilton
Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

CITE's Introduction to U.S. International Tax
Computing Foreign Tax Credit Benefits

Speakers: Frederick Chilton
Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

Northwestern's International Tax Reform in a Reset Economy Symposium
What is Broken with the Current System

Speakers: Robert H. Dilworth
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

CITE's Introduction to U.S. International Tax
Understanding the Subpart F Provisions

Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

UK Tax Update for Multi-National Organisations

Speakers: Peter M.W. Nias , James Ross
Location: Webcast
Practice Areas & Industries: International Tax , London , Tax , Tax - London

TEI New Jersey Chapter Half Day Seminar
Principal Structures under Subpart F, including Contract Manufacturing

Speakers: David G. Noren
Location: Randolph, NJ
Practice Areas & Industries: International Tax , Tax

2009

GW/IRS 22nd Annual Institute on Current Issues in International Taxation
Losses in a Down Economy: International Issues and Planning Responses

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

TEI's International Tax Forum
Update on Principal Structures

Speakers: Sandra P. McGill
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI's International Tax Forum
International M&A and Cross-Border Restructuring

Speakers: Barry J. Quirke , Thomas P. Ward
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax , Tax - Acquisitions & Restructurings

TEI's International Tax Forum
Update on Principal Structures, Legislative Update

Speakers: David G. Noren
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI's International Tax Forum
Transfer Pricing Developments

Speakers: Steven P. Hannes
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax , Transfer Pricing

TEI Santa Clara Valley Chapter Meeting
Subpart F Issues & Update

Speakers: Frederick Chilton , Lowell D. Yoder
Location: Santa Clara, CA
Practice Areas & Industries: International Tax , Tax

Alliance for Tax, Legal & Accounting Seminars (ATLAS)
U.S. Tax Aspects of Cross-Border Acquisitions & Reorganizations

Speakers: Robert A. Clary , II
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

IFA USA Branch - Midwest Region International Tax Seminar
Multi-Jurisdictional Restructuring, Allocations of Multinational Corporate Opportunities and the OECD Discussion Draft on Business Restructurings

Speakers: Steven P. Hannes
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

IFA USA Branch - Midwest Region International Tax Seminar
Event Chair

Speakers: Barry J. Quirke
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI Philadelphia Chapter "Updates and Developments" Conference
Legislative Update: Obama Administration International Tax Proposals

Speakers: David G. Noren
Location: Malvern, PA
Practice Areas & Industries: International Tax , Tax

ABA Tax Section 2009 Joint Fall CLE Meeting
International Legislative Proposals

Speakers: David G. Noren
Location: Chicago, IL
Practice Areas & Industries: International , International Tax , Tax

Networking Seminars Inc.'s Advanced International Tax
Financing Foreign Subsidiaries

Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

2009 International Tax Course (sponsored by TEI)
Foreign Tax Panorama

Speakers: Lowell D. Yoder
Location: Atlanta, GA
Practice Areas & Industries: International Tax , Tax

Fundamentals of Partnership Taxation and International Joint Ventures
Client Presentation

Location: Arlington, VA
Practice Areas & Industries: International , International Tax , Tax

Understanding New IRS Rules that Restrict Profits Overseas

Speakers: Steven P. Hannes
Location: Webcast
Practice Areas & Industries: International Tax , Tax

Advanced International Tax
Financing Foreign Subsidiaries

Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

OECD Consultation on the Discussion Draft on Business Restructurings

Speakers: Steven P. Hannes
Location: Paris, France
Practice Areas & Industries: International Tax , Markets Restructuring , Tax , Tax - Acquisitions & Restructurings

PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances 2009
Implications of Section 704(c) for Negotiating a Partnership Agreement

Speakers: Andrea Macintosh Whiteway
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

ABA-IBA 9th Annual Tax Planning Strategies - United States & Europe Conference
Refinancings and Debt Restructurings

Speakers: James Ross
Location: Amsterdam, The Netherlands
Practice Areas & Industries: Corporate , International Tax , Tax , Tax - London

Switzerland in the International Tax Planning System
Switzerland in International Tax Planning: The German Perspective

Speakers: Dirk Pohl
Location: Geneva, Switzerland
Practice Areas & Industries: Germany , International Tax , Tax

2009 IFA USA Annual Conference
Supply Chain Management: Applying Final & Temporary Contract Manufacturing Regulations

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

District of Columbia Bar Taxation Section's Current Perspectives on Tax Reform

Speakers: David G. Noren
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

2008

The George Washington University's 21st Annual Institute on Current Issues in International Taxation
Chair: The Modernization of Subpart F—Accommodating Business Structures While Preventing Avoidance Transactions

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2008
Cross Border Mergers, Virtual Mergers and Other International Issues

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

University of Chicago Law School's 61st Annual Federal Tax Conference
Domestic Rules in International Transactions-A Bridge Too Far?

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI's 63rd Annual Conference
Hot Topics - Contract Manufacturing & Cost Sharing

Speakers: Lowell D. Yoder
Location: Boston, MA
Practice Areas & Industries: International Tax , Tax

TEI San Francisco Chapter meeting
Recent Developments in Income Tax Treaties

Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

TEI Education Fund's 2008 International Tax Course
Foreign Tax Panorama

Speakers: Lowell D. Yoder
Location: Atlanta, Georgia
Practice Areas & Industries: International Tax , Tax

New York University 2008 Summer Institute in Taxation - Advanced International Taxation session
Foreign Currency Transactions - Opportunities and Risks

Speakers: Andrea S. Kramer
Location: Westin New York at Times Square, New York, NY
Practice Areas & Industries: Financial Products, Trading & Derivatives , International Tax , Tax

TEI's Merge Right, Yield Nothing: Practical Solutions to Challenging International M&A Issues
Structuring and Refinancing the Deal

Speakers: Lowell D. Yoder
Location: The Westin O’Hare in Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI's Merge Right, Yield Nothing: Practical Solutions to Challenging International M&A Issues
How to Move IP to Your Model

Speakers: Sandra P. McGill , James A. Riedy , PC
Location: The Westin O’Hare in Chicago, IL
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute’s International Tax Committee
Subpart F Planning for Sales Income Manufacturing Structures

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI International Tax Committee Meeting
Repatriating Offshore Cash Through Return of Basis

Speakers: Damon M. Lyon , Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

American Bar Association's Global Business Law Conference
International Tax for Dummies: What Transactional Lawyers Should Know About the Tax Aspects of Inbound and Outbound Acquisitions

Speakers: Robert A. Clary , II
Location: The Westin Grand Hotel in Frankfurt, Germany
Practice Areas & Industries: International Tax , Tax

TEI Cleveland Chapter meeting
International Tax-Session A

Speakers: Steven P. Hannes
Location: Marriott Downtown Cleveland, OH
Practice Areas & Industries: International Tax , Tax

TEI Cleveland Chapter meeting
International Tax-Session B

Speakers: Thomas P. Ward
Location: Marriott Downtown Cleveland, OH
Practice Areas & Industries: International Tax , Tax

BNA International's Multinational Companies – Managing the Effective Tax Rate
Taxation of Foreign Profits; Moving and Managing IP Tax Effectively

Speakers: Peter M.W. Nias , Dirk Pohl
Location: London, UK
Practice Areas & Industries: International Tax , Tax

ABA Section of Tax May Meeting
Rangel Bill: The Mother of All Tax Reform

Speakers: Robert H. Dilworth
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

New England Chapter TEI 2008 All Day Meeting
International Topics and Update

Speakers: James Garahan
Location: Sheraton Needham Hotel, 100 Cabot Street, Needham, MA
Practice Areas & Industries: International Tax , Tax

American Bar Association Section of Taxation May Meeting
Proposed Contract Manufacturing Regulations

Speakers: Lowell D. Yoder
Location: Grand Hyatt in Washington, D.C.
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute 58th Midyear Conference
LMSB Going Global: International Examinations

Speakers: Frederick Chilton
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

TEI Seattle Chapter meeting
Contract Manufacturing

Location: Bellevue, WA
Practice Areas & Industries: International Tax , Tax

TEI Seattle Chapter meeting
Foreign Tax Credits

Speakers: Frederick Chilton
Location: Bellevue, WA
Practice Areas & Industries: International Tax , Tax

TEI Seattle Chapter meeting
What's New in 482

Speakers: Paul Dau
Location: Bellevue, WA
Practice Areas & Industries: International Tax , Tax

The Tax Council & Tax Council Policy Institute's 2008 Spring Legislative Conference
International Tax Reform--The Rangel Bill and Other Proposals

Speakers: David G. Noren
Location: Palm Beach, FL
Practice Areas & Industries: International Tax , Tax

36th Annual Conference of the USA Branch of IFA
Legislative/Regulatory Developments in International Tax

Speakers: Robert H. Dilworth
Location: Laguna Niguel, Ca
Practice Areas & Industries: International Tax , Tax

ATLAS—Hot Issues In International Taxation
Hot Topics in Tax: FBCSI Contract Manufacturing Guidance

Location: Las Vegas, NV
Practice Areas & Industries: International Tax , Tax

TEI Los Angeles Chapter Meeting
Contract Manufacturing and Other Principal Structures

Speakers: David G. Noren
Location: Los Angeles, CA
Practice Areas & Industries: International Tax , Tax

TEI Los Angeles Chapter Meeting
International Joint Ventures

Speakers: Thomas P. Ward
Location: Los Angeles, CA
Practice Areas & Industries: International Tax , Tax

TEI Los Angeles Chapter Meeting
Treaties and Other Policy Issues

Speakers: Robert H. Dilworth , David G. Noren
Location: Los Angeles, CA
Practice Areas & Industries: International Tax , Tax

TEI Los Angeles Chapter Meeting
Foreign Tax Credits

Speakers: James A. Riedy , PC
Location: Los Angeles, CA
Practice Areas & Industries: International Tax , Tax

TEI Santa Clara Valley Chapter meeting, Foreign Tax Credits: Overview, Recent Developments and Hot Topics

Speakers: Frederick Chilton , Paul Dau
Location: Santa Clara, CA
Practice Areas & Industries: International Tax , Tax

ABA Section of Taxation 2008 Midyear Meeting
Current Developments Under Subpart F

Speakers: Lowell D. Yoder
Location: Hendersone, NV
Practice Areas & Industries: International Tax , Tax

2007

George Washington Law School's 20th Annual Institute on Current Issues in International Taxation
"Foreign Tax Credit Planning – The Good, The Bad, and The Ugly"

Speakers: James A. Riedy , PC
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

11th Cross Atlantic and European Tax Symposium
Double Tax Treaties - Policy and Practice on Limitation of Benefits and Anti-Abuse Provisions in the US and UK

Speakers: Peter M.W. Nias
Location: London, England
Practice Areas & Industries: Derivatives, Structured Finance and Financial Products , International Tax , London , M&A - London , Mergers & Acquisitions , Structured Finance and Derivatives , Tax , Tax - London

Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2007
"Cross Border Mergers, Virtual Mergers and Other International Issues

Speakers: Lowell D. Yoder
Location: Los Angeles, CA
Practice Areas & Industries: International Tax , Tax

TEI International Tax Forum
Legislative, Administrative and Case Law Developments That Will Impact International Tax Planning

Speakers: Damon M. Lyon , Jean A. Pawlow , Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI International Tax Forum
Update on Treaties with a Primary Focus on Permanent Establishments

Speakers: Sandra P. McGill
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI International Tax Forum
International Tax Planning- Where Are We Headed in Regard to Intangibles and Services

Speakers: David G. Noren , Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

TEI International Tax Forum
International Tax Planning - Where Are We Headed - Foreign Taxes?

Speakers: James A. Riedy , PC
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

ABA Section of Taxation's Joint Fall CLE Meeting
Comparing Canadian and US Tax Procedures - Panelist

Location: Vancouver, BC, Canada
Practice Areas & Industries: International Tax , Tax

TEI's 2007 International Tax Course
Foreign Tax Panorama

Speakers: Lowell D. Yoder
Location: Atlanta, GA
Practice Areas & Industries: International Tax , Tax

Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2007 conference
Panelist - International Joint Venture Issues – Outbound and Inbound General Joint Venture Tax Issues

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

PWC's Spring 2007 Chicago International Tax Forum
Other Recent Developments

Speakers: Robert H. Dilworth
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

PWC's Spring 2007 Chicago International Tax Forum
Recent Developments Affecting Foreign Principal Structures

Speakers: David G. Noren , Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

PWC's Spring 2007 Chicago International Tax Forum
Practical Insights on Tax Reform

Speakers: Robert H. Dilworth
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

International Fiscal Association seminar
The Territoriality Proposals: How Does Ending Deferral Promote Competitiveness?

Speakers: Robert H. Dilworth
Location: Atlanta, GA.
Practice Areas & Industries: International Tax , Tax

TEI New England Chapter Meeting: TEI IRS Administration and Advanced Technology Committees
The Economic Substance Doctrine: 2005-2007 Government Court Victories and Current Legislative Proposals for Codification

Location: Needham, Massachusetts
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute meeting - San Francisco Chapter
Territoriality: Is This Compulsory Cost Sharing for Everyone

Speakers: Paul Dau , Robert H. Dilworth
Location: San Francisco, CA
Practice Areas & Industries: International Tax , Tax

2007 Midyear Meeting, sponsored by the ABA Section of Taxation
Panelist - Important Current Issues under Subpart F

Speakers: Lowell D. Yoder
Location: Hollywood, FL
Practice Areas & Industries: International Tax , Tax

2006

19th Annual Institute on Current Issues in International Taxation
Working With the New Subpart F ‘Look Through’ Rule

Speakers: Lowell D. Yoder
Location: Washington, D.C.
Practice Areas & Industries: International Tax , Tax

Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2006
Cross Border Mergers, Virtual Mergers and Other International Issues

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

53rd Annual Fall Seminar
International Tax Planning Using Section 304: Navigating the Rules

Speakers: Lowell D. Yoder
Location: Rosemont, IL
Practice Areas & Industries: International Tax , Tax

59th Annual Federal Tax Conference
Chairman

Speakers: Lowell D. Yoder
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

Tax Executives Institute’s 61st Annual Conference
Hedging Your Bets: Recent Foreign Currency Issues

Speakers: William R. Pomierski , James A. Riedy , PC
Location: Scottsdale, AZ
Practice Areas & Industries: International Tax , Tax

2006 International Tax Course
Foreign Tax Panorama

Speakers: Lowell D. Yoder
Location: Atlanta, Georgia
Practice Areas & Industries: International Tax , Tax

Subpart F Update
Foreign Base Company Income

Speakers: Paul Dau
Location: Santa Clara, CA
Practice Areas & Industries: International Tax , Tax

Subpart F Update conference

Speakers: Frederick Chilton , Lowell D. Yoder
Location: Santa Clara, CA
Practice Areas & Industries: International Tax , Tax

Tax Treaties: Recent Developments and Emerging Issues
Cross-Border Services: Issues Raised by New Business Models

Speakers: David G. Noren
Location: Watergate Hotel, Washington, DC
Practice Areas & Industries: International Tax , Tax

Tax Treaties: Recent Developments and Emerging Issues
Recent Treaties and Protocols: A Comparative Analysis (Panel)

Speakers: David G. Noren
Location: Watergate Hotel, Washington, DC
Practice Areas & Industries: International Tax , Tax

Chicago Tax Club Summer Seminar
U.S. Domestic Loss Planning

Speakers: Kevin J. Feeley
Location: Chicago, IL
Practice Areas & Industries: International Tax , Tax

Latin America Tax Planning and Controversies
Tax Litigation in Mexico, Brazil, and Colombia Panel

Location: Miami, FL
Practice Areas & Industries: International Tax , Tax

IP Roundtable
IP Holding Company Structures

Location: Palo Alto, CA
Practice Areas & Industries: Intellectual Property , International Tax , IP Litigation , Tax

Tax Executives Institute's 56th Midyear Conference
Recent Developments (Section 987 Regulations, Section 482 Services Regulations, APA Report

Speakers: Lowell D. Yoder
Location: Grand Hyatt in Washington, D.C.
Practice Areas & Industries: International Tax , Tax

Hot Issues in International Tax Conference
Domestic Production Deduction

Location: The Venetian Hotel in Las Vegas, Nevada
Practice Areas & Industries: International Tax , Tax

34th Annual Conference of IFA USA
Manufacturing: Subpart F Exception, Contract Manufacturing, and the International Aspects of the Production Deduction

Speakers: Lowell D. Yoder
Location: Westin Riverwalk Hotel in San Antonio, TX
Practice Areas & Industries: International Tax , Tax

34th Annual Conference of IFA USA
Moderator; The New Cost Sharing Regulations & Their Implications for Intellectual Property and Services & Closing Remarks Speaker

Speakers: Steven P. Hannes
Location: Westin Riverwalk Hotel in San Antonio, TX
Practice Areas & Industries: International Tax , Tax

Current International Tax Issues seminar
International Planning Update

Speakers: James A. Riedy , PC
Location: Troy, MI
Practice Areas & Industries: International Tax , Tax

Subpart F Update
Foreign Base Company Income

Speakers: Paul Dau
Location: Sunnyvale, CA
Practice Areas & Industries: International Tax , Tax

The Practice and Strategic Development of International Business Transactions

Location: Champaign, IL
Practice Areas & Industries: International Tax , Tax

2005

Introduction to U.S. International Tax Conference
Claiming Indirect Foreign Tax Credit

Location: Watergate Hotel, Washington, D.C.
Practice Areas & Industries: International Tax , Tax

New Developments in Foreign Tax Credit Planning
10/31 Foreign Source Losses and their Effect on the Foreign Tax Credit Limitation, and 11/01 Foreign Tax Credit Redeterminations under Section 905 (c)

Speakers: James A. Riedy , PC
Location: Marriott Courtyard in Philadelphia, PA
Practice Areas & Industries: International Tax , Tax

Foreign Currency Transactions-Opportunities and Risks

Speakers: Andrea S. Kramer
Location: Audioconference
Practice Areas & Industries: International Tax , Tax

Summer Institute in Taxation
Foreign Currency Transactions - Opportunities and Risks

Speakers: Andrea S. Kramer
Location: The Westin New York at Times Square
Practice Areas & Industries: International Tax , Tax

Hot Issues in International Tax
International Reorganization Planning (Including §367(b) Planning & Inversions)

Location: he Baker & McKenzie Conference Center
Chicago, IL
Practice Areas & Industries: International Tax , Tax

Tax Aspects of International Acquisitions & Reorganizations
Sections 355 & 367(e)(1)

Speakers: Stephen E. Wells
Location: http://www.atlas-sfi.com/acquisitions_may05/schedule.asp
Practice Areas & Industries: International Tax , Tax

Tax Aspects of International Acquisitions & Reorganizations
Section 367(d) Transfer of Intangibles

Location: Jolly Madison Hotel
New York, NY
Practice Areas & Industries: International Tax , Tax

New England Chapter Meeting
Economic Substance: Recent Cases and Legislative Developments

Speakers: William L. Goldman
Location: Sheraton Needham Hotel
Needham, MA
Practice Areas & Industries: International Tax , Tax

New England Chapter Meeting
The Changing Landscape for Tax Opinions: Auditors Requests for Privileged Documents

Speakers: Robin L. Greenhouse , Michael F. Kelleher
Location: Sheraton Needham Hotel
Needham, MA
Practice Areas & Industries: International Tax , Tax

Societas Europaea - The European Stock Corporation

Location: Munich
Practice Areas & Industries: International Tax , Tax , Tax - Germany

Seventeenth Annual Tax Executives Institute Houston Chapter Tax School
Tax Consequences of Foreign Currency Transactions

Location: Four Seasons Hotel - Houston Center
Houston, Texas
Practice Areas & Industries: International Tax , Tax

Association of Specialized Tax Attorneys' Annual Meeting
New Challenges for Specialized Tax Attorneys

Speakers: Dirk Pohl , Arndt Raupach
Location: Bochum, Germany
Practice Areas & Industries: Germany , International Tax , Tax , Tax - Germany

Recent OECD Initiatives in International Taxation
Attribution of Profits to a Permanent Establishment

Speakers: Steven P. Hannes
Location: The Cosmos Club
Washington, D.C.
Practice Areas & Industries: International Tax , Tax

2004

International Tax Law

Speakers: Dirk Pohl , Arndt Raupach
Location: Deutsches Anwaltsinstitut
Frankfurt, Germany
Practice Areas & Industries: International Tax , Tax

The New International Tax Rules: Opportunities, Surprises and Insider Views
American Jobs Creation Act of 2004

Speakers: Barry J. Quirke
Location: New York, NY
Contact: Susan Tom 203.703.2034
Practice Areas & Industries: International Tax , Tax

University of Illinois College of Law
The Dominance of U.S. and U.K. Laws on International Business Transactions

Location: Champaign, IL
Practice Areas & Industries: International Tax , Tax

Summer Institute in Taxation - Advanced International Taxation Conference
Foreign Currency Transactions - Opportunities and Risks

Speakers: Andrea S. Kramer
Location: The Westin New York at Times Square
New York, NY
Practice Areas & Industries: International Tax , Tax

ATLAS - Tax Aspects of International Acquisitions and Reorganizations
Transfers of Intangibles - Section 367(d)

Location: New York, NY
Practice Areas & Industries: International Tax , Tax

ATLAS - Introduction to International Taxation
U.S. Tax Aspects of Foreign Subsidiary Reorganizations

Location: Baltimore, MD
Practice Areas & Industries: International Tax , Tax

TEI Houston Chapter - Foreign Currency Session
Hedging Transactions and the Straddle Rules: Sections 1092 & 1256

Location: Houston, TX
Practice Areas & Industries: International Tax , Tax

ABA - Tax Section Mid-year Meeting
Planning for and Using Foreign Losses - The U.S. Perspective

Location: Orlando, FL
Practice Areas & Industries: International Tax , Tax

2003

CITE - 11th Annual Conference Series on U.S. International Tax Planning and Compliance Today
Application of New Tax Shelter Regulations to Cross Border Transactions

Location: Atlanta, GA
Practice Areas & Industries: International Tax , Tax

Strategies to Minimise The Risk of Tax Investigations and Disputes

Location: McDermott, Will & Emery, London
Practice Areas & Industries: International Tax , Tax , Tax - London