Attorneys will learn about CFC planning under Subpart F, GILTI regime modifications under OB3, outbound planning for individuals, and cross-border M&A tax considerations.
Attorneys will gain practical strategies for navigating Section 962 elections, 338(g) elections, foreign tax credit limitations, and Pillar Two compliance requirements.
Attorneys will learn about CFC planning under Subpart F, GILTI regime modifications under OB3, outbound planning for individuals, and cross-border M&A tax considerations.
Attorneys will gain practical strategies for navigating Section 962 elections, 338(g) elections, foreign tax credit limitations, and Pillar Two compliance requirements.
Agenda
Session 1
Controlled Foreign Corporation Planning and GILTI Rules
Session 2
Outbound Planning and Entity Choice for Individuals
Session 3
International M&A: Tax Considerations and Planning Techniques
Session 4
Advanced Foreign Tax Credit Rules and Regulations
Session 5
FIRPTA Rules for Foreign Investment in Real Estate
Session 6
Inbound Debt Investing by Foreign Persons
Session 7
Current International Information Return Penalty Issues
8:25 am - 11:30 am EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This comprehensive session examines CFC planning opportunities under Subpart F, including the look-through rule, high-tax exceptions, and earnings and profits limitations. It covers GILTI rules, the impact of the One Big Beautiful Bill Act changes including QBAI elimination, and the restoration of Section 958(b)(4) limiting downward attribution.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
11:45 am - 1:00 pm EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This session addresses the challenges individuals face owning foreign corporations after the Tax Cuts and Jobs Act, including the lack of qualified dividend treatment and indirect foreign tax credits. Participants will explore mitigation strategies including the Section 962 election and interposing U.S. holding companies.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
2:15 pm - 4:30 pm EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This session covers U.S. tax considerations for stock acquisitions of foreign companies, Section 338(g) elections, and CFC issues in deal structures. Topics include the stock buyback tax, qualified stock purchase attribution issues, and OB3 changes affecting interest expense limitations and pro rata share rules.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
8:45 am - 10:15 am EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This session dives into final foreign tax credit regulations, exploring creditability determinations and allocation rules across different baskets. Participants will examine the attribution and cost recovery requirements, treaty coordination rules, and rules for disregarded distributions and dispositions.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
10:30 am - 12:15 pm EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This session addresses the definition of U.S. real property interests and tax rules for foreign persons disposing of such interests. Coverage includes REIT investment rules, exceptions for publicly traded companies and domestically controlled REITs, and exemptions for pension and sovereign investors.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
1:30 pm - 3:00 pm EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This session examines issues relating to foreign person investments in U.S. debt instruments, including U.S. trade or business status determinations. Topics include safe harbors for trading activities, season and sell techniques, and income tax treaty planning including bring your own treaty funds.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
3:15 pm - 4:30 pm EST
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
This session discusses the complex filing requirements for international information returns and the severe penalties imposed for noncompliance. Recent court cases challenging these penalties on technical and reasonable cause grounds are analyzed along with their implications for practitioners.
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Fried, Frank, Harris, Shriver & Jacobson LLP
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
SESSION I
Deposing trucking company personnel…
SESSION II
Defending the Company. Effective Deposition …
SESSION III
Defending the Company. Effective Deposition …
SESSION IV
Defending the Company. Effective Deposition …
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
2:00 – 3:00 PM EST
In trucking accident litigation, plaintiff attorneys must strategically depose key company personnel to uncover negligence, regulatory violations, and systemic misconduct.
This session provides practical deposition strategies to hold carriers accountable and maximize case value. From frontline drivers to senior executives, attendees will learn how to ask precise questions that expose operational lapses, reveal liability patterns, and strengthen plaintiff claims.
Participants will gain tools to challenge unsafe company cultures, evaluate inadequate training and hiring, and document compliance gaps that often lead to catastrophic incidents.
speakers
A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.
Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety. He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.
Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024). He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.
Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.
A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.
Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety. He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.
Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024). He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.
Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.
A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.
Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety. He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.
Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024). He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.
Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.
Andersen Tax LLC
Andersen Tax LLC
EY
EY
Andersen Tax
Greenberg Glusker Fields Claman & Machtinger LLP
Karlin & Peebles, LLPKarlin & Peebles, LLP
Citigroup Global Markets
Alston & Bird LLP
Holland & Knight LLP
National Tax Services, PwC
PwC
New York Law School
Alston & Bird LLP
Holland & Knight LLP
Sean Tevel is a private wealth services and international tax attorney advising foreign and domestic clients on U.S. federal income, gift and estate tax matters associated with their cross-border investments and businesses.
Fried, Frank, Harris, Shriver & Jacobson LLP
Jason Schwartz is a tax partner and co-heads the firm’s Digital Assets and Blockchain Practice, specializing in tax issues relating to financial products, securitizations, funds, treaties, lending, and digital assets.
EY
Kostelanetz LLP
Caplin & Drysdale
McCarter & English, LLP
Kostelanetz
Plans
| Access type | Individual Purchase | Basic | Premium Most Popular | Corporate CLE Plan |
|---|---|---|---|---|
| Price |
$95 – $245
Price varies based
on the course duration of 1 to 3+ hours |
$395/year
One-time purchase
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$495/year
One-time purchase
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Custom
based on firm size
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| Access type | Pay per class | Unlimited annual access | Unlimited annual access | Unlimited access for all firm members |
| Number of Available Webinars | 1 | 1,000+ | 1,000+ | 1,000+ |
| Number of New Webinars Added Yearly | Limited | 500+ | 500+ | 500+ |
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Special credits (Ethics, Elimination of Bias, etc.) |
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| Bootcamps |
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| Access type |
Pay per class |
|---|---|
| Number of Available Webinars | 1 |
| Number of New Webinars Added Yearly | Limited |
| Earn "Live" CLE credit |
|
|
Ability to Ask Questions During the Presentation via a Chat Box |
|
| Attend "Live" Re-Broadcasts |
|
| Exclusive Partner Webinars & Events | |
|
Special credits (Ethics, Elimination of Bias, etc.) |
|
| Instant Certificates After Completion | |
| Personalized CLE Platform | |
| Live Conferences | |
| Bootcamps |
Why Attend
Being an attorney is hard enough without the bookkeeping/IOLTA nonsense. Ready to keep more of what you earn? Whether you’re launching a new law practice or been in your own practice for forty years, this program is your roadmap to slashing your tax bill and building real wealth. Want to write off that second home, or discover how to deduct your vacation? In this dynamic, eye-opening session, civil and criminal tax controversy attorney Eric Green will walk you through often-overlooked strategies to dramatically cut taxes, increase deductions, and protect your law practice from IRS audit adjustments. You’ll walk away armed with actionable insights you can put to work immediately and easily earn back 8-10X what you invested in this seminar!
The program will cover not just how to deduct these expenses but what documentation you need to maintain to make sure you are audit proof if Uncle Sam comes calling!
In this new expanded webinar, Eric and Leighanne will review other benefits like converting your practice to an S Corporation, retirement planning and discuss apps that can help tie all this together and make your record keeping a breeze!
Who Should Attend:
Don’t miss this opportunity to transform the way you think about taxes—and take home the tools you need to save thousands year after year.
Key topics to be discussed:
Closed-captioning available
2025-09-05 13:00:00
This program begins with the foundations of generative AI, introducing large language models and transformer architecture, then moves into practical applications for legal professionals. Participants will learn how to design and deploy custom GPTs in OpenAI and build agent-based automations in Microsoft Copilot, both of which enable legal teams to streamline repetitive work across transactional matters, litigation management, and broader legal operations. The program also highlights how to use OpenAI projects and Microsoft’s integrated tools to scale and organize AI-driven efficiencies across the legal function.
Key topics to be discussed:
Date / Time: December 19, 2025
Closed-captioning available
2025-10-30 14:00:00
Session I – Considerations: Revocable vs. Irrevocable – Georgia Bender
In this session, attorney Georgia Bender will present a brief analysis of the structures and considerations involved in revocable and irrevocable trusts and when each type of trust may be appropriate. Next, Ms. Bender will go into a broad discussion of revocable trusts and the advantages they bring in flexibility of administration, probate avoidance, and estate tax planning. She’ll then review who might be an ideal candidate for this type of trust.
Key topics to be discussed:
Session II – Irrevocable Trusts and Trust Administration – Joseph Donohue
In this session, Attorney Joseph Donohue will review four common types of irrevocable trusts and the contexts in which they are best used. Next, Mr. Donohue will offer some helpful drafting tips for trusts. Lastly, he will dive into topics surrounding trust administration from tax reporting to key phases, avoiding trust contests, and drafting documents to protect your fiduciary clients.
Key topics to be discussed:
Date / Time: December 11, 2025
Closed-captioning available
2026-05-08 14:00:00
FAQ
Yes — the Basic Unlimited Pass gives members access to all online live, replay, and on-demand CLEs, excluding only the live conferences. With the Premium Unlimited Pass, members receive access to over 11 multi-day live conferences as well.
Yes — myLawCLE is an officially accredited CLE provider and seeks CLE approval in all 50 states. Our live webinars, on-demand programs, and replays meet or exceed state bar requirements, ensuring your CLE credits are fully recognized wherever you practice.
Yes — after completing the CLE webinar, attendees select their state for CLE credit and fill out an online evaluation form. Once submitted, a CLE certificate is emailed to them and uploaded to their dashboard.
Yes — myLawCLE develops CLE programs meeting all required CLE types, including mental health, ethics, professionalism, technology, substance abuse, and elimination of bias.
myLawCLE maintains all CLE programs in its library for 12 months following the original broadcast date. Attendees can access any program that remains available in the system during this period.
Yes — all of myLawCLE’s programs are originally broadcast live, with a chat box available for attendees to submit questions during the webinar. Additionally, replays and on-demand versions offer email correspondence with the presenters for any follow-up questions.
Expand Your Legal Expertise
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
Formats
