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

IRS Examination Practices and Strategies
Explanation of the Quality Exam Process that replaces the joint audit planning processes and its significance to LMSB taxpayers. 
 

Successful Tax Practice in China and India
Tips for ensuring proper tax compliance in these countries, transfer pricing considerations, asset transfers, relevance of Vodaphone decision, and more.
 

Getting Proper Research Credit
A review of the significance of recent research credit rulings and tips for ensuring that high technology companies are effectively capturing, documenting and sustaining the research credit upon federal and state examination.
 

International and Multistate Concepts - Similarities, Differences and Traps
A point and counterpoint on international and multistate principles that are similar yet have key distinctions that missed, can cause problems.  Concepts discussed include permanent establishment, nexus, treatment of mobile employees, and audit approaches of these issues by taxing authorities.
 

Economic Substance
After years of proposals, health reform brought about codification of the economic substance doctrine.  How does the new rule work and how will it affect tax planning and IRS examinations?
 

Accounting for Income Taxes and Its Challenges
Topics include buy-ins, valuation allowances, §162(m), foreign exchange/translation, §§988, 986 and 987, functional currency, FIN 48 considerations, FAS 52, hedging and more.
 

Uncertain Tax Positions - Tax Returns and Financial Statements
The new IRS program explained along with tips for effective compliance in line with FIN 48 requirements. Explanation of future work by the IRS in this area and how the new program will affect IRS examinations. Panel will also address implications for the IRC §7525 privilege, work product doctrine and the Textron decision.
 

Cross Border Issues
Transfers of intangibles, cost sharing, future 482 guidance, and legislative proposals concerning intangibles..
 

Cloud Computing Primer
A technological overview along with an explanation of the various international, federal, multistate and local tax issues that come into play and some of the limited guidance that exists.
 

M&A Hot Topics
A review of recent developments relevant to high tech companies, contingent value rights, compensation techniques, GAAP and IFRS implications, IP restructuring, and FAS 141R implications.
 

Federal Domestic and State Tax Updates
Recent developments in R&D, accounting methods, nexus, digital goods, recent legislative activities, as well as the outlook for 2011.