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 introduction to the US taxation of cross-border transactions, focusing on taxation of foreigners investing in the US. Topics will cover: the 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. Limited discussion of taxation of outbound transactions, focusing on CFCs.

Target Audience

Accountants, business managers and CFOs.

Course Objectives

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

Subjects

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

Prerequisites

Completion of an introductory course on international taxation or working knowledge of international tax rules.