2011 TEI International Tax Seminar: U.S. international tax planning in an unsettled policy environment.

Tax Executives Institute will hold its 2011 International Tax Seminar on June 13 and 14 in Chicago. The seminar has been designed to assist tax executives in managing their companies' response to recent U.S. international tax law changes as well as the uncertain prospects for reform of the U.S. international tax system. Tax executives must deal with a multitude of recent and proposed changes to the international provisions of the U.S. tax code while managing their non-U.S. tax risks and structures. The two-day program--to be held at the Hyatt Regency O'Hare Hotel--will cover a wide variety of international tax topics that in-house tax professionals must effectively manage to be successful in today's global economic environment.

The seminar will begin with a discussion of recent and proposed changes to the international provisions of the Internal Revenue Code. The first-in-class faculty will discuss new provisions on covered asset acquisitions and foreign tax credit "splitter" transactions, as well as recent budget proposals to calculate foreign tax credits on a pooled basis and the extension of subpart F to "excess income" from outbound intangible transfers. Next, the registrants will focus on effective income repatriation strategies for U.S.-based companies, including section 1032 transactions and the use of overseas cash to acquired domestic companies, and then turn to international questions and issues faced by in-house international tax professionals who must assist in drafting new Schedule UTP.

The second day of the program will...