International Tax Treaties (Completed)

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This course presents an overview of tax treaties and how they are used in structuring transactions and determining the tax impact of cross-border transactions. It discusses the ordering rules for local laws versus treaty laws, and the purpose of the tax treaties in avoiding and eliminating double taxation to promote trade and investment. The participant will learn about planning opportunities to contemplate when structuring foreign operations.

Who Should Attend
This course is suitable for Corporate tax and finance executives, directors, managers and staff, CPAs, CAs Enrolled Agents, accountants, attorneys and business/financial advisors who work with and advise businesses that have cross-border operations and issues. All in-house and public practice professionals involved with international tax compliance and planning will benefit from this timely and insightful seminar.

Topics Covered

• Territorial vs. Extraterritorial taxation
• Purpose of treaties
• Permanent establishment
• Interpreting treaties

Learning Objectives

• Be able to discuss common treaty provisions in the US Model Treaty
• Understand typical reduced withholding rates on dividends, interest and royalties
• Describe the purpose of income tax treaties in the tax regimes of countries
• Acquire a better understanding of the international tax environment
• Recognize qualifications for a permanent establishment
• Describe the rules by which a taxpayer must disclose a tax position to the IRS for claimed treaty benefits that is in conflict with the IRC
• Ascertain mutual agreement procedures between the taxing authorities of two treaty countries in cases of double taxation
• Recognize when a company/citizen would need to file Form W8-BEN with the IRS in order to claim treaty benefits for US tax withholding

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None