This course presents an overview of tax treaties and how they are used in structuring transactions and determining the tax impact of cross-border transactions. It discusses the ordering rules for local laws versus treaty laws, and the purpose of the tax treaties in avoiding and eliminating double taxation to promote trade and investment. The participant will learn about planning opportunities to contemplate when structuring foreign operations.
This course is suitable for Corporate tax and finance executives, directors, managers and staff, CPAs, CAs Enrolled Agents, accountants, attorneys and business/financial advisors who work with and advise businesses that have cross-border operations and issues. All in-house and public practice professionals involved with international tax compliance and planning will benefit from this timely and insightful seminar.
This event may be a rebroadcast of a live event and the instructor will be available to answer your questions during the event.
Learning Objectives
After attending the presentation you will be able to...
- Acquire a better understanding of the international tax environment.
- Describe the purpose of income tax treaties in the tax regimes of countries.
- Recognize qualifications for a permanent establishment
- Be able to discuss common treaty provisions in the US Model Treaty.
- Understand typical reduced withholding rates on dividends, interest and royalties.
- Describe the rules by which a taxpayer must disclose a tax position to the IRS for claimed treaty benefits that is in conflict with the IRC.
- Ascertain mutual agreement procedures between the taxing authorities of two treaty countries in cases of double taxation.
- Recognize when a company/citizen would need to file Form W8-BEN with the IRS in order to claim treaty benefits for US tax withholding.
Major Topics
The major topics covered in this class include:
- Permanent Establishment
- Limitations on Benefits
- Territorial v. Non-territorial
- Researching treaties
- Interpreting treaty provisions
- Model treaty provisions
- Compliance issues
