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Program Details
2025-07-17 08:45:00
Over 1,000+ webinars
Course Overview
2025-07-17 08:45:00
12h CLE Credits
Intermediate
12
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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. WileyThis 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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. WileyThis 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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. WileyThis 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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. WileyThis 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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. WileyThis 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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. WileyThis 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.
Joseph M. Calianno..
Enrica Ma
Brandon C. Svetcov
Sean Dokko..
Thomas M. Giordano-Lascari..
Michael J.A Karlin
William S. Dixon
Sam K. Kaywood
William B. Sherman..
Adam Bair
J.P. Gregorcy
Alan I. Appel
Heather Ripley
Sean J. Tevel
Jason Schwartz
Matthew Stevens
Megan L. Brackney
Victor A. Jaramillo
Lawrence A. Sannicandro
Melissa L. Wiley
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

PwC

PwC

New York Law School

Alston & Bird

Holland & Knight LLP

Cahill Gordon & Reindel

EY

Kostelanetz LLP

Caplin & Drysdale

Pillsbury Winthrop Shaw Pittman

Kostelanetz

Andersen Tax LLC

EY
Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

EY
Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

Andersen Tax

Greenberg Glusker Fields Claman & Machtinger LLP

Karlin & Peebles, LLPKarlin & Peebles, LLP

Citigroup Global Markets
Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

Alston & Bird LLP
Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Holland & Knight LLP

PwC
Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

PwC

New York Law School
Alan I. Appel specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. He is a Professor of Law at New York Law School and Director of its International Tax Program.

Alston & Bird
Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

Holland & Knight LLP
Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

Cahill Gordon & Reindel
Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

EY
Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

Kostelanetz LLP

Caplin & Drysdale

Pillsbury Winthrop Shaw Pittman
Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

Kostelanetz
Melissa Wiley is a Partner at Kostelanetz LLP with more than 20 years of experience in tax law, having represented a diverse range of clients—from large corporations to high-net-worth individuals—in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, she excels at distilling intricate tax issues into clear, actionable insights, helping clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Melissa serves as a trusted advisor to clients at all levels of administrative tax controversy, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility, and she has significant experience handling penalty and international information reporting matters. When an administrative resolution cannot be reached, she is well-equipped to litigate, and she also represents clients facing government and third-party subpoenas and investigations while frequently advising on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa pairs a scrupulous, detail-oriented approach with a thorough understanding of how tax affects her clients’ financial affairs, and her background in statistics and the insurance industry has fostered a natural ability to collaborate effectively with technical and forensic experts.

Andersen Tax LLC

EY
Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

EY
Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

Andersen Tax

Greenberg Glusker Fields Claman & Machtinger LLP

Karlin & Peebles, LLPKarlin & Peebles, LLP

Citigroup Global Markets
Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

Alston & Bird LLP
Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Holland & Knight LLP

PwC
Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

PwC

New York Law School
Alan I. Appel specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. He is a Professor of Law at New York Law School and Director of its International Tax Program.

Alston & Bird
Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

Holland & Knight LLP
Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

Cahill Gordon & Reindel
Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

EY
Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

Kostelanetz LLP

Caplin & Drysdale

Pillsbury Winthrop Shaw Pittman
Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

Kostelanetz
Melissa Wiley is a Partner at Kostelanetz LLP with more than 20 years of experience in tax law, having represented a diverse range of clients—from large corporations to high-net-worth individuals—in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, she excels at distilling intricate tax issues into clear, actionable insights, helping clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Melissa serves as a trusted advisor to clients at all levels of administrative tax controversy, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility, and she has significant experience handling penalty and international information reporting matters. When an administrative resolution cannot be reached, she is well-equipped to litigate, and she also represents clients facing government and third-party subpoenas and investigations while frequently advising on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa pairs a scrupulous, detail-oriented approach with a thorough understanding of how tax affects her clients’ financial affairs, and her background in statistics and the insurance industry has fostered a natural ability to collaborate effectively with technical and forensic experts.
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.
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