Tax Conferences in July

Tax attorneys Logan Gans, Sean Tevel and William Sherman will be speaking at the NYU School of Professional Studies' Tax Conferences in July. Mr. Gans, Mr. Tevel and Mr. Sherman will present on various taxation topics, including state and local tax issues, partnership taxation, trusts and estates, Subchapter S corporations and international tax matters. Mr. Sherman is also serving as a co-chair for this prestigious conference.

Session Times and Topics

Introduction and Overview
July 15, 2024 | 8:30 – 8:45 a.m.
Speaker: William Sherman

U.S. Taxation of Foreign Persons
July 15, 2024 | 8:45 – 10:15 a.m., 10:30 a.m. – 12:00 p.m.
Speaker: William Sherman

This session will discuss the rules governing source of income, U.S. trade or business, effectively connected income, fixed, determinable, annual and periodic (FDAP) income, Foreign Investment in Real Property Tax Act (FIRPTA), withholding taxes, branch profits tax, branch level interest tax, anti-conduit financing and the base erosion anti-abuse tax (BEAT).

Controlled Foreign Corporations
July 16, 2024 | 8:45 – 10:15 a.m., 10:30 a.m. – 12:00 p.m.
Speaker: Logan Gans

Mr. Gans' panel will examine Subpart F, the main anti-deferral regime of the Internal Revenue Code. The panelists will explore the definitions of a controlled foreign corporation (CFC) and U.S. shareholder, types of Subpart F income, Section 956 inclusions and distributions of previously taxed income. 

Case Studies for Outbound and Inbound Investment
July 17, 2024 | 3:00 – 4:30 p.m.
Speaker: William Sherman

This session will dive into case studies dealing with outbound and inbound investment scenarios. The speakers will reference rules in a variety of tax contexts as well as draw on materials presented during other parts of the program.

International Mergers and Acquisitions: U.S. Tax Considerations and Planning Techniques
July 18, 2024 | 2:15 – 3:30 p.m., 3:45 – 4:30 p.m.
Speaker: William Sherman

Mr. Sherman will talk about U.S. tax considerations for taxable and tax-free stock acquisitions of foreign companies, CFC issues, tax-free acquisitions of U.S. companies, planning for holding companies, inversion transactions, debt-equity regulations, hybrid instruments and other recent developments.

"FIRPTA" Rules and Planning Applicable to Foreign Persons Investing in U.S. Real Estate
July 19, 2024 | 10:30 a.m. – 12:15 p.m.
Speaker: Sean Tevel

Mr. Tevel's panel will explore the definition of U.S. real property interest, tax rules applicable to foreign persons disposing of U.S. real property interests, special rules applicable to investments through real estate investment trusts, special exceptions for interests in publicly traded companies and domestically controlled real estate investment trusts and treaty, and other withholding tax exemptions for payments of interest to foreign investors.