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The Internal Revenue Service recently released final and temporary regulations (the "Regulations") dealing with whether contract manufacturing arrangements entered into by a controlled foreign corporation ("CFC") will constitute manufacturing for Subpart F purposes. Presentation Objectives: In this 60-90 minute presentation, speakers from the government and private sector will review the new Subpart F contract manufacturing provisions, and will: - Explain the reasons for, and the modifications to, the "substantial contributions test.’
- Explain the reasons for, and the modifications to, the Subpart F branch rules.
- Explain the delayed effective date provisions and how taxpayers may choose to apply the Regulations retroactively to open taxable years.
Upon completion of this program, participants will: Understand the policy underlying the modifications to the Substantial Contributions Test of the Proposed Regulations - Know how to apply the Substantial Contributions Test of the Regulations.
- Understand the policy underlying the modification of the branch rules.
- Know how to apply the new branch rules of the Regulations.
- Know what the Regulations do not cover in the branch rule area, why and prospective additions.
- Know how to apply the effective date provisions of the Regulations.
Mr. Granwell moderated the program and Mr. Difronzo provided an explanation of the reasons for and modifications to the regulations. Mr. Calianno provided comments and the panel will suggest planning opportunities and traps for the unwary. Recorded on February 26, 2009, this audio event is available on CD for purchase.
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