A Review of Common Income Tax Treaty Provisions and Uses

Author: Patrick McCormick

CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2025 to receive credits

Join experienced attorney, Patrick McCormick, as he contextualizes the use of income tax treaties in the international tax area. The course begins with an overview of how the United States taxes nonresidents, both conceptually and under statutory rules. Then we provide historical background on United States tax treaties, the ongoing relevance of the U.S. model treaty, and interaction between statutory and treaty rules. The program then delves into specific treaty terms and where/how they are used, including compliance requirements for obtaining treaty benefits.

Publication Date: July 2022

Topics Covered

  • Nonresidents — Income Tax
  • Background Considerations
  • Nonresidents — United States Trade or Business Income
  • Nonresidents — FIRPTA
  • FDAP Income
  • Nonresidents — Income Tax Treaties
  • Income Tax Treaties — Applicable Provisions
  • Noncitizen Non-domiciliaries — Transfer Taxes
  • Estate and Gift Tax Treaties

Learning Objectives

  • Identify how the United States taxes nonresidents under statutory/regulatory rules
  • Recognize how tax treaties alter statutory rules
  • Describe how application of tax treaties to qualified taxpayers can significantly reduce American tax liabilities
  • Recognize the capital gains tax on non-ECI U.S. sourced gains nonresidents are generally subject to
  • Identify how FDAP income applies
  • Recognize what the goal of asset use test and business activities test is to determine whether income is
  • Describe roughly how many countries the United States maintains income tax treaties with
  • Identify the maximum percentage rate of tax applicable regarding noncitizen non-domiciliaries, nonresident individuals receive a $60,000 estate tax exclusion

Level
Basic

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None

Registration Options
Quantity
Fees
Regular Fee $62.00

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