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, 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.
Identify tax issues present in cross-border business transactions and investments.
Determine how to plan for and around international tax issues.
Income tax treaties
Effectively connected income
FDAP and FIRPTA withholding
Avoiding transfer taxation of foreign investors
Pre-immigration tax planning
Accountants, business managers and CFOs.
Completion of an introductory course on international taxation or working knowledge of international tax rules.