Cross Border Finance (Completed)

Date: Thursday, October 28, 2021
Instructor: William J. Seeger
Begin Time:  11:00am Pacific Time
12:00pm Mountain Time
1:00pm Central Time
2:00pm Eastern Time
CPE Credit:  1 hour for CPAs
1 hour Federal Tax Related for EAs and OTRPs
1 hour Federal Tax Law for CTEC

This course is an essential for all practitioners who deal with cross-border tax compliance and planning issues. It is especially important today, as the IRS has aggressively increased scrutiny and enforcement activity in the international tax area.

Who Should Attend
Professionals in public practice and industry will benefit from this program. Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys, and financial advisors who work with and advise businesses and individuals with cross-border operations, activities and issues.

Topics Covered

  • IRS Exam
  • IRS Appeals
  • Advanced Pricing Agreement Program
  • Competent Authority/Mutual Agreement Program
  • BEPS Dispute Resolution procedures
  • Role of Tax Treaties in multi-lateral dispute resolution
  • Dispute resolution planning: the optimal path through the thicket of rules and procedures
  • Leveraging Strategies to control the resolution and outcome of the disputed tax matters

Learning Objectives

  • Recognize how dispute resolution programs work with an emphasis on intercompany pricing
  • Identify opportunities where dispute resolution planning can mitigate audit and tax risk
  • Recognize the relevant steps to employ the essential requirements
  • Differentiate which foreign tax credit is also referred to as the deemed paid credit
  • Recognize and apply the formula for computing the foreign tax credit limitation


Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (1 hour)

Program Prerequisites

Advance Preparation

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