About Jeffrey M. Rosenfeld
Jeffrey Rosenfeld concentrates his practice in the area of business tax law. He counsels public and private corporations, partnerships, and individuals in a broad array of tax matters.
Jeffrey counsels corporate clients and individuals regarding undeclared foreign bank accounts, including “FBAR” reporting obligations, and has represented numerous clients in the Internal Revenue Service’s Offshore Voluntary Disclosure Program.
Jeffrey is a frequent contributor to Blank Rome’s Tax Controversy Watch blog, which focuses on addressing and providing a comprehensive review of the latest developments in the tax controversy field.
Jeffrey obtained his L.L.M. in Taxation from New York University School of Law in 2012. During the 2009–2010 academic year, Jeffrey was a graduate editor for the NYU Journal of Law & Business. While in law school, he volunteered as a tax preparer for Volunteer Income Tax Assistance (“VITA”), and was a student counselor for the Entrepreneurship Legal Clinic.
About Blank Rome LLP
Blank Rome is an Am Law 100 firm with 13 offices and more than 600 attorneys and principals who provide comprehensive legal and advocacy services to clients operating in the United States and around the world. Our professionals have built a reputation for their leading knowledge and experience across a spectrum of industries, and are recognized for their commitment to pro bono work in their communities. Since our inception in 1946, Blank Rome’s culture has been dedicated to providing top-level service to all of our clients, and has been rooted in the strength of our diversity and inclusion initiatives. For more information, please visit blankrome.com.
In October 2018, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations that would exempt certain U.S. controlled foreign corporation (CFC) shareholders from Internal Revenue Code (IRC) section 956 deemed dividend rules.
Although the proposed regulations favor many corporate taxpayers, one must not forget that section 956 still applies. Moreover, not all CFC shareholders covered by section 956 can claim the benefits of the new participation exemption. Inaction in the U.S. Congress is also limiting the scope of the relief provided by the proposed rules. This poses potential pitfalls for the unwary.
In this LIVE Webcast, a panel of key thought leaders organized by The Knowledge Group will provide an overview to help you understand the critical elements of the proposed Section 956 regulations and its potential effects on corporate taxpayers. Speakers will also offer the best strategies on how to maximize the potentials of and mitigate the risks posed by the new participation exemption.
Key topics include:
• The Proposed Section 956 Regulations
• Benefits for Corporate Taxpayers
• Risk Issues and Pitfalls
• Recent Developments
• Best Practices
About The Knowledge Group/The Knowledge Congress Live Webcast Series
The Knowledge Group is a leading provider of Continuing Legal Education, CLE, for lawyers, Continuing Professional Education, CPE, for accountants and a variety of other types of continuing education for other professions. Our mission is to deliver quality continuing education programs utilizing industry trends and the latest technology to communicate regulatory shifts and contributions made to different fields. Our insightful and engaging webcasts are brought to you by leading influencers to offer a multitude of perspectives and outlooks.
In bringing together thought leaders, regulators, and subject matter experts from around the world, The Knowledge Group strives to be the best-in-class provider of continuing education. The experts we engage with analyze the latest trends, insights, and developments in their industries to bring forth content you can’t get anywhere else.
We can be reached via our website, over the phone at (646) 844-0200 or email us at info ( @ ) theknowledgegroup dot org. We look forward to having you learn with The Knowledge Group.
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