International Taxation

Description

The tax consequences of a cross-border transaction can make or break any deal—and CPAs must know the basics and be aware of the traps.

Get an introdution to the U.S. taxation of cross-border transactions. Additionaly, cover U.S. taxation of Americans doing business abroad and taxation of foreigners investing in the U.S.

Topics will cover: controlled foreign corporations; Subpart F income; basics of tax treaties; residency tests; effectively connected income; FDAP withholding; FIRPTA withholding; branch profits tax; ownership structures for non-resident aliens, gift and estate tax planning for foreign investors, and pre-immigration income and estate tax planning.

Highlights

• Controlled foreign corporations
• Subpart F income
• Income tax treaties
• Residence tests
• Effectively connected income
• FDAP and FIRPTA withholding
• Avoiding transfer taxation of foreign investors
• Pre-immigration tax planning

Objectives

• Identify tax issues present in cross-border business transactions and investments.
• Determine how to plan for and around international tax issues.

Designed For

Accountants, business managers and CFOs.