Tax Issues in Puerto Rico Operations Post 936: Including Transfer Pricing, Subpart F, Sec. 367, IRS  (NPR7)

Venue: Caribe Hotel

Location: San Juan, Puerto Rico, United States

Event Date/Time: Oct 02, 2007
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ATLAS - Puerto Rico


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(Alliance for Tax, Legal & Accounting Seminars) presents...


size="6" color="#000080">Tax
Issues in Puerto Rico Operations
Post 936


size="5">Including Transfer
Pricing, Subpart F, Sec 367, IRS

and PR Tax Incentive

November 19 & 20,
2007 - San Juan, Puerto Rico

Caribe Hilton Hotel

Details |  href="">
Accommodations  | href="">Register

This program is an intensive one and half day seminar and workshop on
the U.S., Puerto Rico, and international tax issues facing U.S. and
foreign owned manufacturing businesses based in Puerto Rico but
operating as part of a multi-national enterprise. Section
936 is gone,
so the other rules applicable to U.S. owned controlled foreign
corporations apply: subpart F, transfer pricing, and international
reorganizations, and foreign tax credit, etc. The Commonwealth of Puerto
Rico’s tax rules have taken on a new significance. There is no longer a
presumed unity of taxable income for both U.S. and Puerto Rico purposes.
Moreover, the IRS and other tax authorities are re-examining their
positions in light of the repeal of the relative certainty of section
936. Much has changed, and this program will provide you with an
up-to-date analysis of how existing and proposed laws and rules will
apply to these operations.

You should attend if you are a tax executive responsible for tax
planning and compliance for your enterprise’s international operations,
a financial executive with a tax compliance and planning function
reporting responsibility, or a tax advisor with clients who are thinking
of coming to (or leaving) Puerto Rico, or who are now in Puerto Rico.
This program will acquaint you with—and deepen your knowledge of—the
tools you need to function in a post-Section 936 world. No prerequisite
is required for this basic level course with group live instruction.
This program is transitional which is appropriate for newly admitted

Key Panel Discussion will Focus on:

  • Transfer Pricing Issues

  • Subpart F Issues

  • Section 367 & International

  • Puerto Rico Tax Law in a Post-936

  • IRS Internal and External Guidance;
    936, Transfer Pricing, Section 367

UP TO 11 CPE/CLE Credits
face="Arial">Available.  This course is pre-approved for CLE credits in New York and California.


Issues in Puerto Rico Operations Post
- November
19 & 20, 2007

San Juan, Puerto Rico - Caribe Hilton Hotel


CALL  1-800-207-4432

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$1,295 Early Registration prior to
October 19, 2007

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$1,395 Registration after
October 19, 2007

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$100 Discount for additional registrants from the same company registering
at the same time

(after the initial registrant)

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course materials only.  Please add $50 for shipment outside of the
United States