International High Technology U.S. Tax Current Developments
Comprehensive review of developments relevant to high tech companies
 

Impact of Economic Recession on Audits and Tax Compliance
IRS initiatives and other measures that can bring greater efficiency to the audit process to save time and money, guidelines on dealing with NOL carrybacks, Form 5471 compliance, Circular 230 considerations, new initiatives of the Administration's revenue proposals, and status of the IRS-TEI audit partnership improvement efforts.
 

Clean and Green - Opportunities for High Tech Companies
All levels of government today are promoting the need for greater energy efficiency, use of renewables and the need to address climate change.  Tax incentives and penalties present opportunities for high tech companies both in terms of adopting green practices and new business opportunities.  This panel will also address how a cap-and-trade program at the federal level can affect high tech companies.
 

Cost Sharing and Buy-in Payments - What's New
Dealing with the new regulations effectively, the relevance of recent litigation, and the effect of ARP 51 on intercompany transfers.
 

What's New in Compensation Issues and Planning
Federal tax updates, FAS 141R and 123R considerations, deferred tax accounting, TARP influence on compensation rules, and more.
 

Avoiding Surprises in the Contract Manufacturing Regulations
How to deal with the branch rule changes, treatment of R&D, documentation and more.
 

Withholding - How to Do It Right and the Consequences of Mistakes
Witholding is required in a variety of transactions from employee stock award to international transactions. The IRS LMSB Division places §1441 withholding as a Tier I issues.  Reporting and withholding issues also arise for mobile employees.
 

FAS 109 in Down and Recovering Economics
How to account for recession type items and activities including goodwill impairment, valuation allowances, debt restructuring, commonly encountered issues, and more including the IFRS exposure draft on accounting for income taxes.
 

Recessionary Tax and Cash Planning Opportunities
Dealing with losses, cancellation of debt income, M&A opportunities, loss planning, bankruptcy considerations, decline in values of intellectual property, §988 and §986 planning, form of entity considerations, repatriation of cash, accounting method changes, and more.
 

International Tax Reform
Overview to the Administration's proposals and Congressional reaction, what other countries are doing, what is needed to improve the competitiveness of US firms in the global economy.
 

Consolidated Return Unified Loss Rules
Overview of the application of the consolidated return Unified Loss Rules to dispositions of the stock of a consolidated return subsidiary at a loss or on claiming a worthless stock loss with respect to the stock of a consolidated subsidiary.
 

Federal Domestic and State Tax Updates
Recent developments in R&D, accounting methods, nexus, UDITPA, digital goods, recent legislative activities, as well as the outlook for 2010.