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. **Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to kori.herrera@acpen.com.
Learning Objectives
- Be able to discuss common treaty provisions in the US Model Treaty.
- Understand typical reduced withholding rates on dividends, interest and royalties.
- Describe the purpose of income tax treaties in the tax regimes of countries.
- Acquire a better understanding of the international tax environment.
- Recognize qualifications for a permanent establishment
- 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
- Tax treaties
- Tax impact of cross-border transactions
