CPE: 3 hours
Prerequisites: Completion of an introductory course on international taxation or working knowledge of international tax rules.
Advanced prep: None
Who should attend: Accountants, business managers and CFOs.
The tax consequences of a cross-border transaction can make or break any deal and you must know the basics and be aware of the traps. This course will introduce you to the U.S. taxation of cross-border transactions and cover U.S. taxation of Americans doing business abroad: Controlled foreign corporations; Subpart F income; understanding and selecting treaties; withholding rules; negotiating points for joint ventures; passive foreign investment companies; and foreign tax credits and expatriation. You'll also review residency tests; tax planning for EB-5 investors; pre-immigration income and estate tax planning; connected income; FDAP withholding; FIRPTA withholding; branch profits tax; and ownership structures for non-resident aliens.
- Identify tax issues present in cross-border business transactions.
- Determine how to plan for and around international tax issues.
- Controlled foreign corporations
- Subpart F income
- Income tax treaties
- Residence tests
- Effectively connected income
- FDAP and FIRPTA withholding