International Cross Border Transactions
Author: Allison McLeod
| 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 12/31/2027 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
Join Allison McLeod, CPA, for an introductory course in international cross border transactions. We will discuss typical situations in which a cross-border transaction arises, and how a taxpayer can utilize the rules to potentially decrease an entities effective tax rate. Other issues, such as documentation and IRS audit risk will also be covered. These rules will be illustrated by a hypothetical US-Canada transaction.
Publication Date: August 2024
Topics Covered
- US Entity with Foreign Operations
- Foreign Corporations with US Operations
- Royalties and License Fees
- Inversions
- Cross Border Financing
- Resolving Conflicts
Learning Objectives
- Identify the implications of cross border transaction
- Determine possible exposure issues with profit allocation among different jurisdictions involved in manufacturing, sales or the provision of services
- Explain the different options in resolving transfer pricing controversies, including the use of competent authority, advanced pricing agreements and other alternative methods
- Identify the types of contemporaneous documentation needed
- Determine how to use cross-border transactions to potentially reduce a business' effective tax rate
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
