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 introduction to the U.S. taxation of cross-border transactions, focusing on taxation of foreigners investing in the U.S. Topics will cover: 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.

Highlights

• 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.