On Tuesday, May 20th, I will be speaking at a seminar presented by Bloomberg BNA, entitled U.S. International Tax Reporting & Compliance. Held at the Marriot Biscayne Bay in Miami, the conference will also feature speakers from accounting firms Ernst & Young, KPMG and PwC.

I will be speaking on “Computing the Gain from the Sale of CFC Shares under Section 1248.” I will cover how U.S. taxes gain from the sale of shares in a CFC, how to determine gain on the liquidation of a CFC under Sections 331 and 332, the tax consequences of making a Section 338 election on the sale of a CFC, and will help attendees understand how Section 964(e) applies to dispositions of shares in lower-tier CFCs.

CLE credits are available for attorneys who would like to attend. For more information click here.

By Jeffrey L. Rubinger