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.
Publication Date: October 2021
Designed For
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
- Financial Transactions
- Debt Characterization
- Covered Population
- Intercompany Loans
- Financial Guarantees
- Loans/Guarantees
- Cash Pooling
- Hedging
- Captive Insurance
- Receivables
- Rates of Return
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
- Describe the arm's length principle
- Recognize which relevant factors a taxapayer must consider to determine the arm's length rate
- Describe a captive insurance company
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (1 hour)
Program Prerequisites
None
Advance Preparation
None
Instructor
William J. Seeger
William J Seeger, Ph.D., MJUR is currently Clinical Full Professor of Economics at the University of Texas at Arlington, College of Business Administration, and President of QuantEcon Consulting, an Economic consulting firm. The focus of his academic research is Transfer Pricing and International Tax issues. Upon his retirement in October, 2014, Dr. Seeger was a Principal in KPMG’s Global Transfer Pricing Services practice. He was practice leader, Economic and Valuation Services, for the Dallas, Houston and Denver Business Units and a senior economist and Southwest area lead for KPMG’s Economic Consulting Practice. Dr. Seeger has twenty years of experience in public accounting and three years’ experience with the Internal Revenue Service as an Industry Economist in the Comprehensive Examination Program.