U.S. Source Withholding Tax Rules and Tax Treaty Application (Completed)

This course will cover a discussion of the U.S. withholding tax rules under Chapter 3 (FDAP) of the Internal Revenue Code (IRC), corresponding IRS forms/compliance relating to withholding tax on FDAP, and (Income) Tax Treaty Application (e.g., DTT/Convention).

Who Should Attend
Experienced tax staff through tax director level interested in or already practicing U.S. international income taxation.

Topics Covered

• What are the fundamental U.S. withholding tax rules under Chapter 3 of the IRC?
• What is FDAP?
• What are the basic IRS compliance and potential documentation requirements for U.S. withholding taxation under Chapter 3 of the IRC?
• Tax treaty application and mitigation of the statutory U.S. withholding tax rate

Learning Objectives

• Identify the Chapter 3 U.S. withholding tax rules
• Recognize items of FDAP income
• Recognize IRS forms, compliance, and/or documentation that may be required to report and comply with the U.S. withholding tax rules under Chapter 3 of the IRC
• Recognize that U.S. has income tax treaties (e.g., DTTs or Conventions) with many countries, and applicable treaties may mitigate or eliminate the statutory rate of U.S. source withholding

Level
Intermediate

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Read IRC Sections 871, 881, 1441, and 1461. Read Form 1042-S Instructions.

Advance Preparation
None