Tax Issues in Offshore Manufacturing With Emphasis on Puerto Rico
Including transfer pricing, cost sharing, subpart F,
contract manufacturing, new branch rules, IRS examinations,
and the PR Tax Incentives Act
November 24 & 25, 2008
Courtyard Miami Beach Oceanfront -
Miami Beach, FL
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.