International Corporate Tax Update Event: Repatriation & the Characterization of Debt Instruments

Thu. April 27, 2017

Marks Paneth LLP
685 Third Avenue
New York, NY

As we enter a new year and – with it – a new administration in the White House, there are several tax policy changes taking effect and coming down the pike.

This seminar will discuss two of the most pressing issues that may affect Transatlantic business activities in 2017.
>> Offshore Tax Repatriation
Companies have significant earnings retained offshore that, when repatriated to the US, are subject to US taxation. However, stateside taxes may be offset, to a certain degree, by foreign taxes paid on those earnings – as such taxes may be taken as a credit against US tax.

We will discuss current rules relating to repatriation, as well as recent proposals to reduce tax on repatriations.
Concrete topics of discussion will include:
Foreign tax credit utilization;
• Foreign tax credit utilization after rate reduction;
• Earnings and profits studies;

>>  Debt-Equity Regulations: Managing The Impact Of Section 385
On October 13, 2016, the Treasury Department and IRS released final and temporary section 385 regulations – addressing the characterization of debt instruments as debt or equity for U.S. tax purposes.
Our panel will provide background on the regulations, and discuss how your organization can manage the potential impact on inter-company debt.
Topics to be addressed will include:
What taxpayers can do to protect themselves; and
• Documentation requirements.


 James Robbins, JD, LLM, Marks Paneth LLP
 Joan C. Arnold, 
Partner, Pepper Hamilton LLP
• Michiel van Kempen, Tax Partner, Loyens & Loeff (USA) B.V.
 Brian Jacobs, Head of Tax - Americas, Philips Lighting

8:00 – 8:30 AM Check in
8:30 – 10:00 AM Program
10:00 – 10:30 AM Networking

EACC NY Members: Free of Charge
Non-EACCNY Members: Free of Charge

Featured Speakers

James M. Robbins


8:00 – 8:30 AM Morning Check In
8:30 – 10:00 AM Seminar
10:00 – 10:30 AM Networking Opportunity