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Agenda | International Taxation Seminar | Miami, FL | October 02, 2015
International Taxation Seminar
  1. Foreign Persons Investing in the U.S
    1. Income not effectively connected with a U.S. trade or business
      1. Flat 30% rate 
      2. FDAP income
      3. Source rules
    2. Withholding on FDAP income
    3. Withholding on U.S. real property interest dispositions
    4. U.S. income tax treaties: passive investments
  2. Foreign Persons Doing Business in the U.S.
    1. Income effectively connected with a U.S. trade or business: taxed on a net basis
    2. Branch profits tax
    3. Withholding on income from U.S. partnerships: Section 1446
    4. U.S. income tax treaties: business investments
    5. Section 482: transfer pricing issues, inbound
  3. Alternative Planning Structures for Foreign Investors: Income Tax Considerations
  4. U.S. Persons Doing Business Offshore
    1. Domestic corporation
    2. Taxation of worldwide income
      1. Relief from double tax
      2. Foreign tax credit
    3. Section 911 exclusion
    4. Section 482: transfer pricing issues, outbound
    5. Withholding: outbound
    6. Section 367: taxation on transfers
    7. Income taxed in U.S. when repatriated
    8. Repeal of foreign person holding company rules
    9. Controlled foreign corporations
      1. Ownership test
      2. Current taxation under Subpart F
      3. Foreign tax credit
  5. U.S. Income Tax Compliance Rules for Offshore Activities and Accounts
  6. Expatriation Rules
    1. Prior law
    2. Current law in general
    3. Income tax planning considerations
    4. Estate tax planning considerations
  7. International Estate Planning
    1. Jurisdiction issues
      1. Resident vs. nonresident
      2. Estate tax domicile vs. income tax residence; citizenship
    2. Foreign inheritance law issues
    3. Property situs issues
    4. Credits, deductions, date of death basis adjustments (including QDOTs)
    5. Estate tax treaties
    6. Pre-immigration planning
  8. U.S. Estate and Gift Tax Compliance Rules for Offshore Trusts, Bequests, and Gifts
  9. Alternative Planning Structures for Foreign Investors: Estate Tax and Asset Protection Considerations