David Rosenbloom Speaks at Tax Lecture Series on Tax Planning for U.S Inbound Investment
H. David Rosenbloom
"13th Annual NYU/KPMG Tax Lecture Series"
April 18, 2013
NYU School of Law
This symposium explores U.S. tax implications and planning strategies with respect to the life cycle of foreign investment in the United States, both under U.S. domestic tax law and income tax treaties. Mr. Rosenbloom will first discuss U.S treaty benefits and developments and later participate in a debate panel regarding U.S domestic treaty overrides.
Topics, among others, will include:
- Primer on U.S. inbound taxation – portfolio investment and business income
- Planning under U.S. tax treaties – including application of the authorized OECD approach to determining income attributable to a U.S. permanent establishment
- Domestic tax law treaty overrides- are we going against our word?
- Financing into the U.S. corporate group – both from a U.S. and selected foreign countries' perspectives
- Foreign acquisition of a U.S. group – inversions, post acquisition restructuring
- Taxation of U.S. branches of foreign corporations at the federal, state, and local levels
- FIRPTA planning, including inbound REIT structuring
U.S. taxation of foreign governments and sovereign wealth funds