• Plan amendments, processes, and procedures due on December 31 – bringing alignment between form and function.
• What to do if things go wrong – calculation corrections and possible remedial actions.
• Proposed regulations dealing with calculation of penalty taxes and determination of income inclusion as a result of violating the regulations.

• Complexities of new documentation, nondiscrimination rules, vendor relationships, and regulatory requirements.
• Applicability of new annual reporting rules, including audit readiness and annual Form 5500 requirements.
• Board member responsibilities and risks, including confirming plan compliance.
• How retirement services providers are responding to changes.

• Analyzing possible financial statement effects of IFRS with regard to compensation and benefits programs, including executive compensation, health and welfare, and retirement programs.
• Evaluating the potential impact of IFRS accounting on the operation of your rewards programs, especially those driven by corporate financial performance.
• Assessing IT and process changes, including information gathering, reporting, and internal controls.

• Special tax rules applicable to ESOPs for C corporations and S corporations, including deferral of gain by a selling shareholder and taxation of the business.
• Plan considerations for and financing of an acquisition, disposition, or a leveraged buyout.
• Benefits of employee ownership to shareholders, management, and employees, including interest alignment and improved motivation.

• Stock compensation trends, including restricted stock units and the impact of increasing corporate governance.
• International pressures on U.S. companies, including differences in tax treatment in China, India, and other key countries.
• Plan considerations, including leading practices for restricted stock units and policies and procedures.

• Legal entity structure issues, including allocation timing differences, tax-sharing agreements, and federal, state, and foreign tax filings.
• Scope issues affecting the financial statement audit, including the tax provision, inventory of deferred items, the potential need for a valuation allowance, and documentation.
• Other potential tax issues, including deferred taxes, taxes payable, tax rates, tax contingencies, and FIN 48 liabilities.

• Common weaknesses in tax provision processes, including tight timelines, data collection, and reliance on spreadsheets.
• Leading practices for improving the tax provision process, including the integration of current payable reconciliations, deferred tax account validations, alignment with compliance, and automation.
• Risk mitigation through the better management of people, process, and technology.

Mergers and Acquisitions: Why Tax Accounting Will Never Be the Same Again

• How the new statements affect tax accounting for uncertain tax positions, deferred taxes, and valuation allowances.
• Tax consequences at transition for past and prospective acquisitions.
• Fine-tuning tax due-diligence practices, including pressure points on effective tax rate, FIN 48 liabilities, and valuation allowances.

• Background and objectives of the project.
• Summary of the key differences between FAS 109 and IAS 12 that are proposed to be eliminated, and differences that may remain, including accounting for uncertainty in income taxes.
• Overview of the comment letter process and how to get involved.

• Direct and indirect uses of built-in losses and earnings and profits deficits.
• Unexpected consequences of loss recognition.
• Maintaining flexibility when profits are unpredictable.

• Luxembourg – recent tax planning ideas involving financing, intellectual property, holding, repatriation, trading, and private equity structures for multinational companies.
• Italy – tax basis step-up opportunities in extraordinary transactions and the new interest limitation deduction rules.
• Key developments in other foreign jurisdictions.

• Brazil – issues associated with multinational companies investing and financing operations in Brazil, as well as repatriating profits.
• France – current trends in France under the new Sarkozy administration; and an update on R&D credits and the participation exemption regime.
• Key developments in other foreign jurisdictions.

• Legislative developments relating to a possible extension.
• Impact of the potential sunset on intercompany financing transactions and structural alternatives.
• Transactions that should be considered in light of the potential sunset of this provision.

• Key provisions, including a two-year suspension of net operating loss deductions and limitations on use of credits to offset tax liability.
• A 20 percent penalty on underpayment of taxes in excess of $1 million on or after January 1, 2003.
• The silver lining, including an extended NOL carryover period, two-year NOL carryback, and assignment of tax credits to combined reporting group members.

• An overview of U.S. taxation of inbound investment, including rules of permanent establishment, effectively connected income, and FDAP – fixed, determinable, annual, or periodic income.
• Key state tax considerations – nexus versus permanent establishment, computing state taxable income, and earnings repatriation.
• Addressing exposure – location and timing of credits and incentives, possible hybrid and reverse-hybrid structures, and organizational issues.

• Recent sales factor market sourcing and increased sales factor weighting changes.
• New unitary combined reporting and consolidated filing methods.
• Working through the maze of safe harbor exceptions to the now more than 20 states that disallow certain related party expenses.

• Recent sales factor market sourcing and increased sales factor weighting changes.
• New unitary combined reporting and consolidated filing methods.
• Working through the maze of safe harbor exceptions to the now more than 20 states that disallow certain related party expenses.

• Assessing your overall vision and strategy for business succession and related issues, including identifying and preparing future leaders.
• Talents and skills the successor management team will need, and strategies and leading practices for addressing gaps.
• A case study illustrating how unseen obstacles can stall progress

• An overview of the U.S. wealth-transfer tax system and potential costs to private enterprise owners who don't plan ahead.
• How successful families have traditionally passed wealth through trusts and other tax-efficient vehicles.
• Why lower business valuations and interest rates near historic lows may provide favorable conditions for launching tax-efficient succession plans now.

• The global landscape — key drivers forcing mid-sized and private companies to address their globalization strategy.
• The primary challenges and opportunities to consider as your company evaluates expanding it’s global footprint.
• International tax considerations that may impact your global plan.

• Penalties most often asserted by examiners during an IRS examination.
• Potential defenses against these penalties.

• Innovative approaches for deploying tax personnel more efficiently.
• Establishing and fine-tuning project management, work plans, budgets, status reporting, and updates for key processes.
• Technology considerations, including methodologies for storing electronic work papers and tactics and tools for aligning tax technology with the provision process.
• Improving collaboration between tax and accounting personnel, systems, and processes.

• Opportunities – and potential pitfalls – of using technology to support the year-end accounting process.
• Approaches for global data collection and management, including software selection and implementation, data identification, configuration, and data interfaces.
• Fine-tuning the tax organization to be more scalable and agile.

• Obama’s individual tax proposals, including the fate of 2001 tax cuts, tax increases for top-earners, tax relief for lower wage-earners, and estate taxes.
• Business tax increases intended to restore fairness to the tax code and other changes designed to protect and grow U.S. jobs and address energy production and efficiency.
• Areas of uncertainty for clients including international tax, capital gains and losses, and compensation and benefits.

• JTPF achievements regarding a simplified pan-European transfer pricing approach.
• The EU Arbitration Convention's Code of Conduct – does it help taxpayers eliminate double taxation?
• The master file approach to EU transfer pricing documentation – is it improving compliance efficiency and is it a model for global documentation?
• Perspectives of individual governments and how the results of the EU Forum are implemented in practice.

• Hungary – advantages of and strategies for obtaining Advanced Pricing Agreements, the increasing focus on and sophistication of documentation reviews, especially benchmarking data, stronger penalties for documentation shortfalls, and tips for resolving audit issues through Competent Authority.
• Poland – pros and cons of applying for an APA, including certainty for strategic investments in a market with high penalty regime.

• Germany has new lower tax rates, but new rules also increase the tax burden on companies that shift operations to lower cost countries. How do you manage your position?
• Mexico's new flat tax may increase the tax cost of Mexican operations. How does the new IMMEX program offer opportunities to better manage Mexican profits?

• Changes at the Canada Revenue Agency and updates on CRA positions regarding the penalty regime, audit positions, and qualified CCAs.
• CRA positions on U.S service regulations, royalty payments, intangibles, recharacterizations, foreign exchange, and plant closures.
• Options for appeals, Competent Authority, and APAs.
• The impact of current court cases on audit activity.

State and Local Transfer Pricing: Not a Time for Complacency

• Legislative and litigation updates, and value chain structures that companies are using today.
• Issues states are attacking under audit, including economic substance, contractual gaps, and stale transfer pricing analyses.
• What companies can do to assess risks, steps for reducing exposure, options for strengthening structures, and addressing specific scenarios.

• U.S. audit landscape — hot audit issues, including an update on cost sharing.
• Foreign audit trends — widely varying methodology and documentation requirements in various countries and how to manage them.
• Strategic audit considerations.

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